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The Ironic Impact of FinCEN’s New CTA Regulations on New York’s LLC Transparency Act

The NYS LLC Transparency Act (the “New York Act”) became law in January 2024 and takes effect on January 1, 2026. When in effect, it would require limited liability companies formed or qualified to do business in New York to...more

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

With the Preliminary Injunction of the Corporate Transparency Act Stayed, FinCEN Extends Deadlines for Compliance

The Fifth Circuit Court of Appeals has stayed the preliminary injunction issued on December 3, 2024, in the Texas Top Cop Shop case by a U.S. District Court. As a result, the original beneficial ownership reporting...more

Corporate Transparency Act: Is Your Company Prepared to Meet the Deadline for Filing on January 1, 2025?

Beneficial Ownership Reports are filed electronically through the Financial Crimes Enforcement Network. Individuals who need to be reported as beneficial owners or company applicants should apply for a FinCEN ID number....more

FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

FinCEN Extends Beneficial Ownership Reporting Deadline for Companies Created or Registered in 2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a rule that extends the deadline from 30 days to 90 days for reporting companies created or registered in 2024 to file initial beneficial...more

CFPB Finalizes Small Business Lending Data Rule

A far-reaching new federal regulation will for the first time require small business lenders to collect detailed data about applications and originations, and report that data to the Consumer Financial Protection Bureau...more

Federal Regulators Adopt New Computer-Security Incident Notification Requirements for Banks and Service Providers

In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more

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