On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more
3/3/2025
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
New Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Temporary Hold
Earlier this week, the Financial Crimes Enforcement Network (FinCEN) issued a new notice confirming that the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements are back in effect....more
As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more
1/24/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
Compliance ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
National Security ,
NPRM ,
Pending Legislation ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Trump Administration
As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the Corporate Transparency Act (CTA)...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays
The Corporate Transparence Act was a part of landmark anti-money laundering legislation passed in 2021. It was designed to shift reporting of corporate ownership from a hodgepodge of different financial institutions to the...more
June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more
8/5/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Penalties ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On March 1, 2024, New York Governor Kathy Hochul signed an amended version of the New York LLC Transparency Act (NYLTA), which was originally signed with provisions for amendments in December 2023. The NYLTA will go into...more
The CTA and Legal Challenges -
The CTA is a sweeping new anti-money-laundering law that, as of January 1, 2024, requires most entities formed or registered to do business in the United States to disclose detailed...more
As discussed in our prior Update on the Corporate Transparency Act (CTA), anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial...more
The Corporate Transparency Act (CTA), designed to combat the use of shell companies for illicit purposes and increase ownership transparency in corporate structures, takes effect on January 1, 2024. As discussed in more...more
Key portions of the Corporate Transparency Act (CTA) will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the...more
12/11/2023
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more
12/5/2023
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Business Ownership ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Exemptions ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Reporting Requirements
The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more
10/4/2022
/ AML/CFT ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Jurisdiction ,
Limited Liability Company (LLC) ,
Penalties ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated proposed rule that would implement key provisions of the Corporate Transparency Act (CTA), a...more
On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more
9/22/2021
/ Anti-Money Laundering ,
Anti-Retaliation Provisions ,
Bank Secrecy Act ,
BSA/AML ,
Corporate Transparency Act ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Employees ,
Financial Institutions ,
Money Laundering ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Whistleblower Awards ,
Whistleblowers
As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more
7/15/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Disclosure Requirements ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
New Rules ,
Reporting Requirements ,
Terrorist Financing Regulations ,
U.S. Treasury