News & Analysis as of

Beneficial Owner Compliance

Winstead PC

The Corporate Transparency Act Requires Reporting of Beneficial Owners

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The Corporate Transparency Act (the "CTA") became effective on January 1, 2024, requiring many corporations, limited liability companies, limited partnerships, and other entities to register with and report certain...more

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Mayer Brown Free Writings + Perspectives

Accelerated Schedule 13G Reporting Deadlines Effective September 30

The Securities and Exchange Commission’s accelerated Schedule 13G filing deadlines become effective September 30, 2024. On October 10, 2023, the SEC adopted changes to Schedules 13D and 13G relating to beneficial ownership...more

Stark & Stark

Corporate Transparency Act (CTA): Action Required for Community Associations

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As the end of the year approaches, there has been no determination that community associations will be relieved of the requirement to comply with the Corporate Transparency Act (CTA). While we remain hopeful of a legislative...more

Fox Rothschild LLP

The Clock Is Ticking on the Corporate Transparency Act's Year-End Deadline

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Have you or your professional advisers evaluated whether any entities you own, manage, or control are subject to the beneficial ownership reporting requirements of the Corporate Transparency Act (CTA)? If you've done so and...more

Polsinelli

Accountancy and the Corporate Transparency Act

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The Corporate Transparency Act (CTA) is a new, federal, legal reporting and compliance regime touching on the ownership and control of covered reporting companies operating in the United States. These reporting companies are...more

Holland & Knight LLP

FinCEN Issues Additional Helpful Guidance on How to Report a Dissolution of a Company

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Sept. 10, 2024, issued four FAQs to update and clarify how reporting should be undertaken for reporting companies that are dissolved prior...more

Fenwick & West LLP

New Schedule 13G filing deadlines looming

Fenwick & West LLP on

New filing deadlines for Schedule 13G become effective on September 30. In October 2023, the SEC adopted new rules governing beneficial ownership reporting, including accelerating the filing deadlines for Schedule 13G and...more

Venable LLP

Looming Reporting Deadline Under the Corporate Transparency Act: The Reality Sets In

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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

Conyers

The Impact of Cayman’s Revised Beneficial Ownership Regime on Trusts and Private Wealth Structures

Conyers on

The Cayman Islands is in the process of implementing fundamental changes to its beneficial ownership regime. Most significantly, these include the removal of exemptions applicable under the previous regime, as well as more...more

Parker Poe Adams & Bernstein LLP

The Corporate Transparency Act: Key Deadline Fast Approaching and Other Recent Updates for Companies

If your business has not yet focused on the Corporate Transparency Act (CTA), it is time to do so. Every entity formed or registered in the U.S. before January 1, 2024, must file beneficial ownership information (BOI) reports...more

Kerr Russell

Don’t Overlook Corporate Transparency Act Compliance

Kerr Russell on

Question: My accountant and other are telling me there is some federal government filing that I must make by the end of the year. My personal information is being sought. Can you explain what this is all about, whether I have...more

Seward & Kissel LLP

SEC Settles Charges with a Publicly Traded Company and its Controlling Shareholder for Not Disclosing Pledge of Company’s...

Seward & Kissel LLP on

Who may be interested: Board of Directors; Registered Investment Advisers; Registered Investment Companies; Broker-Dealers; Transfer Agents; Compliance Staff - Quick Take: The SEC announced that it settled charges against...more

Mandelbaum Barrett PC

Navigating the Corporate Transparency Act: Reporting Requirements and Compliances Strategies for Small Businesses

Mandelbaum Barrett PC on

On January 1, 2024, the Corporate Transparency Act (the “CTA”) became effective and imposes reporting obligations which impact millions of small businesses across the United States. Although the CTA is currently the subject...more

Farella Braun + Martel LLP

All Roads Lead to FinCEN Identifiers

For any reporting company with modest complexity in terms of ownership and management, it will become apparent that requiring FinCEN Identifiers for all beneficial owners will be the only practical path forward for compliance...more

Manatt, Phelps & Phillips, LLP

Complying with the Corporate Transparency Act

Under the Corporate Transparency Act (CTA), as of January 2024 many corporations, limited liability companies, limited partnerships, and similar legal entities are now required to report ownership and management information...more

Smith Anderson

The Corporate Transparency Act - New Guidance on Reporting Obligations

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As discussed in our three prior client alerts, effective as of January 1, 2024, the Corporate Transparency Act (“CTA”) and rules issued thereunder by the Financial Crimes Enforcement Network (“FinCEN”) require most U.S....more

Holland & Knight LLP

The (Uncertain) Application of the Corporate Transparency Act to Tribal Entities

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The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury (Treasury Department) charged with administering the Corporate Transparency Act (the CTA), on Aug. 1, 2024, held a Tribal...more

BCLP

CTA and Corporate Governance: A Quick Guide for Situations Where CTA Comes into Play

BCLP on

The Corporate Transparency Act (“CTA”) was enacted by The U.S. Congress in January 2021 as a way to protect the United States financial system from being used for money laundering and other illicit activities....more

Perkins Coie

Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations

Perkins Coie on

June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's July 2024 Round-Up

Holtzman Vogel attorneys wrote on the Supreme Court's landmark Loper Bright decision earlier this month. The Court overruled its 1984 decision in Chevron v. NRDC that introduced the so-called "Chevron deference" principle...more

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Winstead PC

Triggers That Require Reporting Companies to File Updated Beneficial Ownership Interest Reports

Winstead PC on

On January 1, 2024, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 and its annual National Defense Authorization Act....more

Holland & Knight LLP

FinCEN Issues New Guidance on Reporting Company Filing Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 8, 2024, issued additional FAQs1 providing guidance on Reporting Company filing requirements under the Corporate Transparency Act...more

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