On March 21, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued its "Interim final rule; request for comments" that removes any requirement for U.S. companies or U.S. persons to submit beneficial...more
Just when you thought the dust was settling, the U.S. Department of the Treasury (Treasury Department) issued a press release on Sunday, March 2, in connection with the rollout of the Corporate Transparency Act (CTA)....more
Another curveball has been thrown in the never-ending back-and-forth surrounding the rollout of the Corporate Transparency Act (CTA). As detailed in our prior client memo, a federal district court in Texas issued a nationwide...more
All eyes were focused on how the U.S. Supreme Court (SCOTUS) would respond to the application for stay filed by the federal government on New Year's Eve seeking a stay of the preliminary nationwide injunction issued by a...more
After a rollercoaster ride last week, the Corporate Transparency Act's (CTA) nationwide preliminary injunction remains in place for the immediate future, pending further review by the U.S. Court of Appeals for the Fifth...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
As detailed in our prior client memo regarding Texas Top Cop Shop, Inc. v. Garland, the federal district court in the Eastern District of Texas (Sherman Division) issued an order for a nationwide preliminary injunction...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, the federal district court in the Eastern District of Texas issued an order (Order) for a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop...more
Over three years ago, Congress enacted the federal Corporate Transparency Act ("CTA"), which for the first time obligates business owners, among others, to file beneficial ownership information ("BOI") reports with the U.S....more
9/10/2024
/ Beneficial Owner ,
Compliance ,
Constitutional Challenges ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Final Rules ,
FinCEN ,
Pending Litigation ,
Regulatory Requirements ,
Reporting Requirements
The Corporate Transparency Act (CTA), which became effective on January 1, 2024, was enacted to combat the use of shell companies by those seeking to evade anti-money laundering laws and economic sanctions. ...more
3/8/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Commerce Clause ,
Compliance ,
Constitutional Challenges ,
Corporate Transparency Act ,
Economic Sanctions ,
Fifth Amendment ,
Financial Crimes ,
FinCEN ,
First Amendment ,
Foreign Entities ,
Fourth Amendment ,
Injunctions ,
Reporting Requirements ,
Shell Corporations ,
Small Business
Beginning January 1, 2024, the Corporate Transparency Act (CTA) will take effect and impose an obligation on many U.S. entities (and foreign entities doing business in the United States), unless exempted, to report to the...more
The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more
12/8/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Centers for Medicare & Medicaid Services (CMS) ,
Corporate Transparency Act ,
Covered Entities ,
Disclosure Requirements ,
Exemptions ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
Foreign Entities ,
Health Care Providers ,
Healthcare Facilities ,
Medicaid ,
Medicare ,
National Security ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
Federal law will soon require for the first time that certain companies disclose personally identifiable information about themselves and their beneficial owners and company applicants to U.S. Treasury’s Financial Crimes...more