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CTA Compliance Stay Continues Despite Supreme Court Lifting Nationwide Injunction; FinCEN Recognizes Separate District Court Stay...

On January 23, 2025, the U.S. Supreme Court granted the government’s motion to lift the nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop Shop v. McHenry (formerly, Texas Top...more

CTA Preliminary, Nationwide Injunction Reinstated; FinCEN Suspends Compliance with CTA; Briefing Schedule on the Merits...

On December 26, 2024, a three-judge “merits panel” for the U.S. Court of Appeals for the Fifth Circuit vacated the December 23, 2024, order issued by a separate three-judge “motions panel,” which had granted the government’s...more

The U.S. Court of Appeals for the Fifth Circuit Grants the Government’s Emergency Motion for a Stay of the District Court’s...

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the U.S. government’s motion for a stay of a preliminary (nationwide) injunction of the Corporate Transparency Act (“CTA”) pending appeal....more

Federal District Court in Texas Grants “Nationwide” Preliminary Injunction Against CTA Enforcement

On December 3, 2024, the United States District Court for the Eastern District of Texas entered a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (“CTA”) and its implementing...more

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

Request for Comments on FinCEN and SEC rule on CIP

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

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