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FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

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

FinCEN Announces No Penalties for BOI Reporting Failures

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

FinCEN Commits to Extend CTA Reporting for 30 Days If Court Grants Stay of Injunction

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

FTC’s Final Rule Requires Reporting of Data Breaches by Non-Bank Financial Institutions

On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more

Federal Reserve Board Adopts Final Version of LIBOR Transition Rule

As previously noted in our August 30, 2022 alert, the Board of Governors of the Federal Reserve System (the FRB) published a proposed regulation to implement the Adjustable Rate (LIBOR) Act (the Act). As explained in the...more

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