As promised, FinCEN has adopted its interim final rule and narrowed the filing requirements for Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (“CTA”). This rule exempts U.S. entities...more
4/8/2025
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Disclosure Requirements ,
Domestic Corporations ,
Filing Deadlines ,
FinCEN ,
Foreign Corporations ,
Reporting Requirements ,
U.S. Treasury
FinCEN and the Department of the Treasury both provided updates this week regarding the Corporate Transparency Act....more
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are now back in effect. As a result, all entities subject to the CTA are once again obligated to file BOI reports with...more
Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
This is still a developing matter. On December 23, 2024, the Fifth Circuit issued an order that has the effect of reinstating FinCEN’s ability to enforce the CTA and the looming December 31 deadline to file reports for any...more
After our December 23 News Alert, FinCEN announced an extension for all filings due by 12/31/2024 for entities formed prior to January 1, 2024. Such subject entities now must file no later than January 13, 2025....more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Injunctions ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementation of regulations nationwide....more
On January 1, 2024, the new reporting requirements under the Corporate Transparency Act (the “CTA”) took effect in the United States. The CTA, aimed at increasing corporate transparency and combating financial crimes,...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act. The new legislation requires certain entities...more
Recent Enforcement Action -
The requirement that financial firms preserve books and records is nothing new. But how do such firms keep track of employees’ communications on applications like Signal or WhatsApp? Those...more
This coming year will have a revamped ADV with some new requirements. A significant new consideration is the challenges that new cryptocurrencies and other digital assets present for investment advisers and their compliance...more