As discussed in our previous client advisory, earlier this month, the U.S. District Court for the Northern District of Alabama entered a final declaratory judgment concluding that the Corporate Transparency Act (“CTA” or the...more
On January 1, 2024, the new beneficial ownership information reporting requirements (BOIR) went into effect under the Corporate Transparency Act (CTA). Among other things, beneficial ownership reporting is intended to make it...more
The Corporate Transparency Act (CTA), which becomes effective on January 1, 2024, creates novel obligations for millions of entities to report beneficial ownership information (BOI) and certain other information to the U.S....more
Under the Corporate Transparency Act (CTA), which we have previously written about, reporting companies are required to report to the Financial Crimes Enforcement Network (FinCEN) certain identifying information about...more
The US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published its Small Entity Compliance Guide (the “Guide”) for the Corporate Transparency Act (the “CTA”) on September 18, 2023. The Guide...more
On January 1, 2024, the Corporate Transparency Act (the “CTA”) comes into effect for reporting companies formed after that date, with reporting for existing companies taking effect a year later. With approximately six months...more
On September 9, 2022, the Securities and Exchange Commission (the “SEC”) adopted a number of inflation-related adjustments under the Jumpstart Our Business Startups Act (the “JOBS Act”), including an adjustment to the revenue...more
As COVID-19 (coronavirus) continues to spread globally and governments and companies take efforts to slow and contain the virus, no company is able to continue “business as usual.” ...more
On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) announced that it will begin accepting applications for special-purpose national bank charters from financial technology companies (“fintech”). A...more
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules which codify customer due diligence requirements for financial institutions (the “CDD Rule”)[1] under the Bank Secrecy Act (the “BSA”). ...more
FinCEN Exchange to encourage information sharing
In December 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced the creation of a platform to facilitate information sharing on a voluntary...more
In December 2017, FINRA issued Regulatory Notice 17-42 to request comments on its proposed amendments to the procedures relating to requests to expunge customer dispute information from the Central Registration Depository...more
On May 11, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) Final Rule codifying new and existing customer due diligence (“CDD”) requirements under the Bank Secrecy Act (“BSA”) was...more