On April 9, 2025, the Markets Participants Division and the Division of Market Oversight (collectively, the “Divisions”) of the Commodity Futures Trading Commission (the “CFTC”) published a Staff Letter (the “Staff Letter”)...more
On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more
3/27/2025
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Final Rules ,
FinCEN ,
Foreign Corporations ,
Foreign Entities ,
Interim Final Rules (IFR) ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business
On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies...more
On February 27, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take other enforcement actions for a failure to comply...more
On February 18, 2025, U.S. District Judge Jeremy Kernodle of the Eastern District of Texas stayed his prior injunction against enforcement of the Corporate Transparency Act (the “CTA”) pending appeal by the U.S. Department of...more
On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more
On January 23, 2025, the U.S. Supreme Court ruled that the federal government may enforce the Corporate Transparency Act (“CTA”) while the Fifth Circuit continues to review a constitutional challenge to the law. Previously,...more
On December 26, 2024, the Fifth Circuit of the United States Court of Appeals vacated the stay of the injunction on the Corporate Transparency Act (the “CTA”) that a panel had issued earlier in the week. As a result, the...more
On December 23, 2024, the Fifth Circuit of the United States Court of Appeals (the “Fifth Circuit”) issued an order that has the effect of reinstituting the deadlines under the Corporate Transparency Act (the (“CTA”). On...more
The Corporate Transparency Act (CTA) requires all corporations, limited liability companies, limited partnerships, and many other entities created or registered to do business in any U.S. state to file a beneficial ownership...more
On December 3, 2024, the United States District Court for the Eastern District of Texas issued a nationwide injunction against enforcement of the Corporate Transparency Act (the “CTA”). The CTA requires a range of entities,...more
The Corporate Transparency Act (the “CTA”) requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network...more
11/1/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
CFTC ,
Corporate Transparency Act ,
Exemptions ,
Financial Crimes ,
FinCEN ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Subsidiaries ,
U.S. Treasury
On July 8, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs with respect to the beneficial ownership reporting requirements of dissolved entities. The Corporate...more
Following the financial crisis of 2007-2009 and congressional investigations into the securitization market, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 prohibited securitization participants from...more
On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (the “CTA”) is unconstitutional, leaving its future uncertain. The CTA requires...more
In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other...more
2/14/2024
/ Anti-Terrorism Financing ,
Beneficial Owner ,
Corporate Transparency Act ,
FinCEN ,
Healthcare ,
Law Enforcement ,
Management Agreements ,
Money Laundering ,
National Intelligence Agencies ,
National Security ,
Notice of Non-Compliance ,
Penalties
On January 12, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs in response to questions received regarding compliance with various aspects of the Corporate...more
On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more
1/10/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Confidentiality Agreements ,
Corporate Transparency Act ,
Financial Institutions ,
FinCEN ,
National Security ,
Penalties ,
Popular ,
Regulatory Violations ,
Reporting Requirements ,
SRO ,
U.S. Treasury
On December 13, 2023, the Securities and Exchange Commission (“SEC”) adopted new rules that will have the effect of requiring central clearing of a broad range of cash transactions and repurchase transactions in U.S. treasury...more
In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more
12/29/2023
/ Beneficial Owner ,
Corporate Transparency Act ,
FinCEN ,
Foreign Corporations ,
Full-Time Employees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Parent Corporation ,
REIT ,
Reporting Requirements ,
U.S. Treasury
The SEC has been sued again in the U.S. Court of Appeals for the Fifth Circuit, on the heels of that Court’s recent invalidation of the SEC’s newly-minted corporate buy-back rules. The new legal action asks the Court to...more
Following the financial crisis of 2007-2009 and Congressional investigations into the securitization market, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 prohibited securitization participants from...more
Today, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule aimed to ease compliance with certain aspects of the regulations promulgated under the Corporate Transparency Act. The...more
On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 10c-1a (the “Securities Lending Rule”), requiring the reporting of certain securities lending transactions. Certain material terms of...more
10/30/2023
/ Broker-Dealer ,
Confidential Information ,
Consolidated Audit Trail ,
EU ,
Financial Industry Regulatory Authority (FINRA) ,
Loans ,
Over The Counter Derivatives (OTC) ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
SFTR ,
TRACE ,
UK
On October 13, 2023, the Securities and Exchange Commission adopted new Rule 13f-2 to require monthly reporting of short sale positions and activity data on new Form SHO by institutional investment managers. The new rules...more