Compliance Perspectives: Rolling Out New Compliance Initiatives
On January 8, 2025, the U.S. Department of Justice (DOJ) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by countries...more
On April 17, 2025, the Centers for Medicare and Medicaid Services (CMS) formally announced an extension for the mandatory off-cycle revalidation deadline for skilled nursing facilities (SNFs)....more
Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC announced a two-year extension to the effective and compliance dates for rule amendments...more
Circular Action Alliance to accept reports through April 30, 2025 - Circular Action Alliance (CAA) recently announced a grace period through April 30, 2025 for producers to report data by weight and material category for all...more
Established under the Cyber Security Act 2024 (the ‘Act’), the Cyber Security (security standards for smart devices) Rules 2025 (the ‘Rules’) set out the requirements for three security standards introduced to enhance the...more
On March 14, 2025, the SEC announced a six-month extension of the compliance dates for its previously adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (known as the Names Rule). The compliance date is...more
The Treasury Department announced that it will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing Corporate Transparency Act regulatory deadlines....more
CTA Update - On February 27th, 2025, FinCEN put out a release stating they will not be issuing any fines or penalties or take any other enforcement actions against any companies based on a failure to file beneficial...more
FinCEN and the Department of the Treasury both provided updates this week regarding the Corporate Transparency Act....more
The Corporate Transparency Act was passed in 2021 and took effect January 1, 2024. The purpose of the act is to help combat money laundering, fraud, and terrorism by requiring certain non exempt private companies to report...more
In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing...more
The Federal Deposit Insurance Corporation (FDIC) is further postponing the compliance date requirements to display the FDIC official digital sign on an insured depository institution’s (IDI) digital channels, as well as on...more
On February 27, 2025, FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for “those entities...more
In a press release on March 2, 2025, the U.S. Department of the Treasury announced that it will not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
In a major shift in policy, just days after the Financial Crimes Enforcement Network (“FinCEN”) announced that it would pause enforcement of the beneficial ownership information (“BOI”) reporting requirements under the...more
On March 2, 2025, the U.S. Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens. The Department indicated...more
On February 27, 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) announced that it intends to issue an interim final rule by March 21, 2025, with extended beneficial ownership information reporting deadlines. It...more
Strap in—Corporate Transparency Act (the “CTA”) compliance has taken yet another unexpected turn. Just as companies were gearing up to meet the March 21st deadline for filing beneficial ownership information (“BOI”) reports...more
As we noted in our February 20, 2025, client alert, unless the Financial Crimes Enforcement Network ("FinCEN") or Congress decided to take action by March 21, 2025, the beneficial ownership information ("BOI") reporting...more
In a release dated March 2, 2025, the Treasury Department has indicated that all enforcement of the Corporate Transparency Act (the “CTA”) against United States citizens and domestic reporting companies will be suspended,...more
On February 18, 2025—after a flurry of litigation and uncertainty surrounding the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements—FinCEN set a new mandatory reporting...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
Having only announced its extended March 21, 2025 deadline to file beneficial ownership information reports under the Corporate Transparency Act (“CTA”) last week, on February 27, 2025, FinCEN confirmed that it would “not...more
In a bombshell release issued on Feb. 27, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced that it will not impose any fines or penalties or take any other enforcement...more
Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more