Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more
On Sunday, March 2, 2025, the U.S. Department of Treasury announced, with respect to the Corporate Transparency Act (CTA), that it will not enforce penalties or fines for beneficial ownership information (BOI) reporting...more
On February 27, 2025, FinCEN announced “it will not issue any fines or penalties or take any other enforcement actions against companies based on any failure to file or update beneficial ownership information (BOI) reports...more
2/28/2025
/ Beneficial Owner ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement Actions ,
Final Rules ,
FinCEN ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more
2/7/2025
/ Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Enforcement Actions ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more
1/27/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
SCOTUS ,
Stays
In a rollercoaster of a ride, the merits panel of the U.S. Court of Appeals for the Fifth Circuit, on December 26, 2024, vacated the prior order of the Fifth Circuit’s motions panel staying the preliminary injunction...more
The United States Court of Appeals for the Fifth Circuit on December 23, 2024, issued an order lifting a prior order issued by a federal district court in the Eastern District of Texas granting a nationwide preliminary...more
12/30/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
Much has been written about the filing requirements under the Corporate Transparency Act (CTA) in the last year. Currently, enforcement of the CTA has been placed on hold. On December 3, 2024, a federal district court in the...more
On December 5, 2024, the Department of Justice (DOJ), on behalf of the Department of the Treasury, filed a Notice of Appeal to the Fifth Circuit challenging the nationwide preliminary injunctive relief from compliance with...more
The Corporate Transparency Act (CTA) is unconstitutional, according to a March 1, 2024, ruling by Judge Liles Burke of the U.S. District Court for the Northern District of Alabama. The National Small Business Association...more
Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more
1/3/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
CEOs ,
CFOs ,
Corporate Transparency Act ,
Doing Business ,
Domestic Corporations ,
Financial Crimes ,
FinCEN ,
Foreign Corporations ,
National Security ,
Ownership Interest ,
Penalties ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations