On March 21, FinCEN announced an IFR that removes U.S. companies and U.S. citizens from the scope of the reporting requirements under the CTA....more
The CTA is not dead, but it is hanging by a thread.
On March 2, the U.S. Treasury Department (the Treasury) issued a press release announcing significant updates to the plans announced by FinCEN just a few days earlier....more
Continuing on its roller coaster of the past few months, CTA compliance is effectively back on hold after FinCEN announced that it plans to further extend the existing reporting deadlines. Below, we address some of the key...more
On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more
2/20/2025
/ Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
Final Rules ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions ,
U.S. Treasury
On Feb. 5, the U.S. government filed (i) a notice of appeal of the order issued Jan. 7 by a U.S. District Court in Texas in Smith v. U.S. Department of Treasury, No. 6:24-cv-336-JDK (E.D. Tex. Jan. 7, 2025), which had issued...more
In yet another twist, the CTA is again currently enjoined (for now). On Dec. 26, in a highly unusual chain of events, the merits panel of the Fifth Circuit Court of Appeals vacated the emergency stay granted by the motions...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
On Dec. 23, 2024, the Fifth Circuit Court of Appeals granted the government’s motion for an immediate stay pending appeal of the preliminary injunction issued on Dec. 3, 2024, by a federal district court in Texas....more
On Dec. 11, 2024, the U.S. government filed a motion requesting an immediate stay of the preliminary nationwide injunction issued last week by a federal district court in Texas that temporarily halted the implementation of...more
12/16/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Constitutional Challenges ,
Corporate Governance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On Oct. 10, the U.S. Securities and Exchange Commission (SEC) announced that it adopted final rules amending Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, as amended. The amendments aim to provide investors...more
What is the Corporate Transparency Act?
The CTA will require all “reporting companies” to disclose certain information on their beneficial owners to FinCEN....more
Key takeaways - The Corporate Transparency Act (CTA) will create a new, confidential database of beneficial owners of private companies for use by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network...more