As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically...more
On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more
3/7/2025
/ Beneficial Owner ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting...more
On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more
1/29/2025
/ Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Injunctions ,
Reporting Requirements ,
SCOTUS
As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a...more
As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the...more
The Financial Crimes Enforcement Network (“FinCEN”) has announced temporary relief measures for reporting companies affected by recent hurricanes in the Southeast, providing additional time to comply with Beneficial Ownership...more
In a key development relating to the Corporate Transparency Act (the “CTA”), on March 1, 2024, U.S. District Judge Liles C. Burke of the Northern District of Alabama issued a memorandum opinion and final judgment ruling the...more
The Corporate Transparency Act (the “CTA”), a new federal law, went into effect on January 1, 2024 (see our update and summary here). In the weeks since, the Financial Crimes Enforcement Network (“FinCEN”) has continued to...more
The Corporate Transparency Act (the “CTA”), a new federal law, went into effect on January 1, 2024. The CTA requires that certain entities file Beneficial Ownership Information Reports (“BOI Reports”) with the Financial...more
Update: On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). The House had already voted to override the veto. The NDAA and its...more
The National Defense Authorization Act for FY 2021 (“NDAA”) passed Congress on December 11, 2020, with a “veto-proof” margin. Included within the NDAA are a number of anti-money laundering provisions with import for companies...more
12/17/2020
/ Anti-Money Laundering ,
Corruption ,
Disclosure ,
Disclosure Requirements ,
FinCEN ,
Foreign Banks ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Limited Liability Company (LLC) ,
NDAA ,
Reporting Requirements ,
U.S. Treasury ,
Whistleblowers
Recently, BuzzFeed News and the International Consortium of Investigative Journalists (“ICIJ”) reported on a 16-months’ long investigation into a trove of explosive documents apparently leaked from the U.S. Financial Crimes...more