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Constitutional Challenges Reporting Requirements Enforcement Actions

Thomas Fox - Compliance Evangelist

FCPA Compliance Report: Death of CTA

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode, Tom welcomes back Corporate Transparency Act expert and maven Jonathan Wilson for a look at how the Trump...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

Holland & Hart LLP on

The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Allen Matkins

Will Ling Chi Kill The Corporate Transparency Act?

Allen Matkins on

Ling Chi was a slow and torturous method of execution practiced in Imperial China.  Better known in English as "death by a thousand cuts", ling chi took a terribly long time to kill the condemned prisoner....more

White & Case LLP

US Supreme Court Rejects Application of Commingling Theory in Holocaust Expropriation Case

White & Case LLP on

On February 21, 2025, the US Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, further narrowing the scope of the Foreign Sovereign Immunities Act's exception to sovereign immunity for expropriation...more

McNees Wallace & Nurick LLC

“The Corporate Transparency Act is Unconstitutional”, Whispered a Federal Court in Michigan

Days after the United States Treasury Department and its Financial Crimes Enforcement Network (FinCEN) announced it was suspending enforcement the Corporate Transparency Act (CTA), (you can read about that in our last client...more

Foster Garvey PC

FinCEN Delivers Some Good News About Its Enforcement of the Corporate Transparency Act

Foster Garvey PC on

On Thursday, February 27, 2025, FinCEN announced that it will not issue any penalties or pursue enforcement action against reporting companies for the mere failure to meet the current filing deadlines. That news for many is...more

Wiley Rein LLP

Treasury Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

Wiley Rein LLP on

Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking - On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more

Kelley Drye & Warren LLP

Treasury Department Halts Enforcement of CTA Reporting Obligations

On March 2, 2025, the U.S. Treasury Department announced that it would not enforce penalties or fines associated with beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA)...more

Cozen O'Connor

FinCEN Pauses Enforcement Actions under CTA

Cozen O'Connor on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not take enforcement actions against any companies for failure to file or update beneficial ownership information (BOI) reports...more

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act - UPDATED February 21,2025

Husch Blackwell LLP on

As of the posting of this article, reporting companies nationwide once again need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. FinCEN has set the...more

Polsinelli

Important Update – Corporate Transparency Act Filing Obligations Reinstated and Mandatory

Polsinelli on

CTA filings are obligatory again. Most reporting companies have until March 21, 2025 to complete their filings. If you adopted a wait-and-see posture in regard to making your CTA BOIR filings, the wait is unfortunately over....more

DLA Piper

CTA Update: Reporting Rule Reinstated; FinCEN Imposes March 21 Reporting Deadline for Most Reporting Companies

DLA Piper on

On February 17, 2025, the US District Court for the Eastern District of Texas stayed its previous order suspending enforcement of the Corporate Transparency Act (CTA)’s Reporting Rule in Smith v. US Dept. of the Treasury,...more

Eversheds Sutherland (US) LLP

And just like that—the Corporate Transparency Act is back!

The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted. The Corporate...more

Lowndes

Return of the CTA – FinCEN Once Again Able to Enforce Filing Requirements

Lowndes on

The beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. The CTA generally requires “reporting companies” (any domestic or foreign entity registered...more

Hinshaw & Culbertson LLP

URGENT UPDATE: Corporate Transparency Act Reporting Requirements Back in Effect – What You Need To Know

Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...more

Orrick, Herrington & Sutcliffe LLP

Court stays a medical debt credit reporting case against CFPB

On February 13, the U.S. District Court for the Southern District of Texas stayed a lawsuit against the CFPB regarding the CFPB’s medical debt reporting final rule. The final rule, which the CFPB finalized in early January,...more

Paul Hastings LLP

New York State Bill Seeks to Impose Greenhouse Gas Emissions Disclosure Requirements

Paul Hastings LLP on

On January 27, 2025, N.Y Sen. Brad Hoylman-Sigal (D), introduced Senate Bill 3456 (“SB 3456”) calling for the adoption of the Climate Corporate Data Accountability Act (“CCDAA”). The bill is substantively identical to...more

Flaster Greenberg PC

Corporate Transparency Act Updates

Flaster Greenberg PC on

(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...more

McGlinchey Stafford

FinCEN Commits to Extend CTA Reporting for 30 Days If Court Grants Stay of Injunction

McGlinchey Stafford on

On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more

Bass, Berry & Sims PLC

Supreme Court Enters the Corporate Transparency Act Fray, But Enforcement and Filings Remain on Hold

Bass, Berry & Sims PLC on

On January 23, the U.S. Supreme Court lifted the nationwide injunction entered by the federal district court in the Eastern District of Texas in the case styled Texas Top Cop Shop v. McHenry, which had barred enforcement of...more

Morris, Manning & Martin, LLP

Supreme Court Intervenes in CTA Legal Battle, But Implementation Still on Hold Due to Separate Injunction

The Supreme Court has weighed in on the ongoing battle concerning the Corporate Transparency Act (the CTA). As we previously wrote, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Says Reporting Obligations Remain On Hold

Last Friday, the United States Supreme Court lifted a nationwide injunction originally issued by the U.S. District Court for the Eastern District of Texas (and later upheld by the Fifth Circuit Court of Appeals) in Texas Top...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

Verrill on

FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...more

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