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
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
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