The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more
3/27/2025
/ Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Disclosure Requirements ,
Enforcement Actions ,
Final Rules ,
FinCEN ,
Foreign Corporations ,
Foreign Entities ,
Interim Final Rules (IFR) ,
New Legislation ,
Regulatory Requirements ,
Reporting Requirements
After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more
3/12/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
Popular ,
Reporting Requirements ,
SCOTUS ,
U.S. Treasury
On December 26th, just three days after the United States Court of Appeals for the Fifth Circuit effectively reinstated reporting obligations under the Corporate Transparency Act (CTA), the Fifth Circuit has now vacated its...more
On December 23, 2024, the United States Court of Appeals for the Fifth Circuit terminated the nationwide preliminary injunction originally issued by the United States District Court for the Eastern District of Texas,...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction barring enforcement of the Corporate Transparency Act (CTA)1 and its key implementing regulations...more
12/6/2024
/ Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement ,
Financial Crimes ,
FinCEN ,
First Amendment ,
Fourth Amendment ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
Texas ,
Unconstitutional Condition
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
8/21/2024
/ Bank Secrecy Act ,
Bribery ,
CFTC ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Failure to Comply ,
False Claims Act (FCA) ,
Federal Contractors ,
Financial Institutions ,
FinCEN ,
Fraud ,
Healthcare Fraud ,
Incentives ,
Internal Reporting ,
Investigations ,
Money Laundering ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers
On November 7, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced in an Enforcement Information that Apollo Aviation Group, LLC (Apollo), a Florida-based commercial aviation...more
12/2/2019
/ Aircraft ,
Aviation Industry ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Equipment Lease ,
Leases ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Sudan ,
Supply Chain ,
U.S. Treasury ,
Ukraine ,
United Arab Emirates (UAE)
On October 11, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on Ashraf Seed Ahmed Hussein Ali, a Sudanese national widely known by his pseudonym “Al-Cardinal,” pursuant...more
10/18/2019
/ Blocked Person ,
Bribery ,
Corruption ,
Economic Sanctions ,
Executive Orders ,
Fraud ,
Fraudulent Procurement ,
Global Magnitsky Act ,
Government Officials ,
Human Rights ,
Kickbacks ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
SDN List ,
Sudan ,
Trump Administration ,
US State Departments