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Treasury announces there will be no penalties or fines for failure to file CTA beneficial ownership reports and proposes to narrow...

Key takeaways FinCEN and Treasury announce that there will be no enforcement for failure to file beneficial ownership information reports with FinCEN by the March 21 deadline. Treasury announced intention to narrow the scope...more

CTA reporting requirements reinstated with March 21, 2025 deadline for most non-exempt reporting companies

As described in our previous client alert, on January 23, 2025, the Supreme Court of the United States stayed the nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas...more

CTA Required Reporting Still on Hold: Recent Supreme Court ruling affects one CTA beneficial ownership case, but other case...

Key takeaways TLDR: No mandatory BOI/CTA filing yet, but stay tuned pending resolution of a second case and subsequent FinCEN guidance. On January 23, 2025, the Supreme Court of the United States stayed the nationwide...more

Fifth Circuit dissolves CTA injunction; FinCEN extends filing deadline

On December 23, 2024, the Fifth Circuit Court of Appeals dissolved a district court injunction that had stayed the January 1, 2025 deadline for compliance with the Corporate Transparency Act (“CTA”). Therefore, the Fifth...more

U.S. District Court suspends enforcement of Corporate Transparency Act (CTA) and FinCEN implementing regulations

On December 3, 2024, the U.S. District Court for the Eastern District of Texas suspended the enforcement of the U.S. Corporate Transparency Act (“CTA”) and its implementing regulations for “reporting companies” issued by the...more

Corporate Transparency Act declared unconstitutional in Alabama federal court

The court issued a permanent injunction against enforcement by the U.S. Department of the Treasury and its Financial Crimes Enforcement Network (FinCEN) of the Corporate Transparency Act (CTA) for the named plaintiffs only....more

FinCEN proposes expanding Bank Secrecy Act requirements to certain investment advisers

On February 13, 2024, U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a Notice of Proposed Rulemaking seeking to expand the Bank Secrecy Act’s definition of “financial institution” to include...more

U.S. Corporate Transparency Act beneficial ownership reporting regulations take effect January 2024

The U.S. Congress enacted the Corporate Transparency Act (CTA) in 2020. The CTA for the first time created a federal obligation to report beneficial ownership information for most U.S. entities (and foreign entities doing...more

U.S. regulators issue joint notice concerning SAR key term and global evasion of trade controls

On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more

CTA regulations set to take effect in January 2024 with obligations for some private fund sponsors

Effective January 1, 2024, new Treasury regulations under the Corporate Transparency Act (CTA) will require many U.S. entities and foreign entities doing business in the United States to report identifying beneficial owner...more

US regulator updates and expands guidance on beneficial ownership reporting requirements

The US Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a Small Entity Compliance Guide to aid in understanding and complying with the Corporate Transparency Act’s beneficial ownership information reporting...more

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