News & Analysis as of

Corporate Transparency Act

K&L Gates LLP

UK Government's Fraud Strategy Framework: 2026 to 2029

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On 9 March 2026, the UK government published the Fraud Strategy 2026–2029: Disrupting crime, supporting economic resilience and delivering justice (the Strategy), replacing the 2023–2025 framework. The Strategy commits over...more

Ankura

FinCEN Eases Beneficial Ownership Verification for Financial Institutions

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In a significant regulatory update, the Financial Crimes Enforcement Network (FinCEN) has announced a new order granting relief to financial institutions from the stringent requirements of verifying beneficial owners every...more

DLA Piper

FinCEN Issues Exceptive Relief From Beneficial Ownership Identification And Verification Requirements At Each Account Opening

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On February 13, 2026, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) granting certain banks, mutual funds, brokers, and dealers exceptive relief from the...more

Seward & Kissel LLP

Domestic LLCs Escape New York’s Transparency Act

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Good news for domestic limited liability companies in New York. On December 19, 2025, Governor Hochul vetoed amendments that would have decoupled the New York Limited Liability Company Transparency Act (“NY LLCTA”) from the...more

Mintz - Venture Capital & Emerging Companies...

Update to New York LLC Transparency Act (NYLTA)

The New York LLC Transparency Act (NYLTA) has been amended to apply only to limited liability companies (LLCs) that were formed outside of the United States but are registered to do business in the state of New York. The law...more

Dickinson Wright

FinCEN Simplifies CDD Requirements for Financial Institutions

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On February 13, 2026, FinCEN issued an Order providing “exceptive relief” to covered financial institutions (including banks, savings associations, and broker-dealers). The order simplifies the requirements for obtaining...more

Kohrman Jackson & Krantz LLP

Navigating KYC and AML Compliance After FinCEN’s Beneficial Ownership Updates

Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements form the foundation of the United States’ framework for preventing money laundering, terrorist financing and other forms of financial crime. For banks,...more

Orrick, Herrington & Sutcliffe LLP

FinCEN grants ‘exceptive relief’ from certain customer due diligence requirements under 2016 rule

On February 13, FinCEN issued an order granting “exceptive relief” to covered financial institutions from the requirement under the 2016 CDD rule to identify and verify the beneficial owners of a legal entity customer at each...more

Ballard Spahr LLP

FinCEN Provides CDD Relief for New Account Openings

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On February 13, 2025, FinCEN issued an order granting exceptive relief for covered financial institutions from certain Customer Due Diligence (“CDD”) requirements for new account openings. The exceptive relief is part of...more

Troutman Pepper Locke

FinCEN Eases Beneficial Ownership Requirements Under CDD Rule

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FinCEN has issued an order granting exceptive relief from the longstanding requirement that covered financial institutions (CFIs) identify and verify the beneficial owners of legal entity customers every time a new account is...more

Harris Beach Murtha

Answering Five Questions About New York’s LLC Transparency Act

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The landscape for New York limited liability companies has changed in 2026 and non-U.S. LLC owners must comply with new regulations....more

Mintz

FinCEN Eases Beneficial Ownership Verification Requirements: What Financial Institutions Need to Know

Mintz on

On February 13, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an exceptive relief order that significantly reduces customer due diligence (CDD) requirements for financial...more

Cole Schotz

FinCEN Finalizes New Residential Real Estate Reporting Rule Effective March 1, 2026

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Beginning March 1, 2026, a new Residential Real Estate Rule from the Financial Crimes Enforcement Network (“FinCEN”) will require federal reporting of certain residential real estate transactions. The rule expands...more

King & Spalding

FinCEN Limits Beneficial Ownership Review for Subsequent Account Openings

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On February 13, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exceptive relief order that streamlines customer due diligence (CDD) requirements for financial institutions...more

Sands Anderson PC

How New FinCEN Reporting Requirements Will Affect Certain Real Estate Transfers Beginning March 2026

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Significant regulatory changes are coming to the real estate industry. Starting March 1, 2026, any LLC, corporation, trust, or similar entity that purchases residential property may be required to disclose detailed ownership...more

Woods Rogers

What Should CRE Owners and Investors Know About FinCEN’s New Transaction Reporting Rules?

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Federal oversight of commercial real estate transactions is increasing. Beginning in 2025 and 2026, new reporting requirements issued by the Financial Crimes Enforcement Network (FinCEN) will require certain real estate...more

Hinckley Allen

The New York LLC Transparency Act Became Effective January 1, 2026

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New York has implemented a new beneficial ownership reporting regime (the “New York LLC Transparency Act” or “NYLTA”), effective January 1, 2026, which only applies to limited liability companies (“LLCs”) that were formed...more

Cranfill Sumner LLP

The Eleventh Circuit Upholds the CTA, But the Compliance Picture Remains Unsettled

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On December 16, 2025, the U.S. Court of Appeals for the Eleventh Circuit in National Small Business United v. U.S. Department of the Treasury held that the Corporate Transparency Act (CTA) is constitutional....more

Offit Kurman

New York’s LLC Transparency Act Now in Effect

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New York Governor Kathy Hochul signed the New York Limited Liability Company Transparency Act (“NY LLCTA”) into law in December 2023. Under the NY LLCTA, covered companies became subject to certain new reporting requirements...more

Moritt Hock & Hamroff LLP

New York Limited Liability Company Transparency Act In Effect As Of January 1, 2026, But Its Applicability Is Currently Limited

Enacted in late 2023, the New York Limited Liability Company Transparency Act (the “NYS CTA”) goes into effect on January 1, 2026. Modeled on the federal Corporate Transparency Act (the “Federal Act”), the NYS CTA was...more

Loeb & Loeb LLP

New York LLC Transparency Act Update: Scope of Reporting Requirements Substantially Narrowed

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As discussed in our December 2025 client alert, New York LLC Transparency Act to Impose New Reporting Requirements, the New York State Legislature passed a bill (S.8432/A.8662A) amending the New York LLC Transparency Act to...more

Orrick, Herrington & Sutcliffe LLP

Eleventh Circuit upholds Corporate Transparency Act reporting rules

Recently, the U.S. Court of Appeals for the 11th Circuit reversed a lower court’s ruling and upheld the constitutionality of the Corporate Transparency Act (CTA), a federal law requiring certain corporations, limited...more

Dickinson Wright

CTA – Where Does It Stand Today?

Dickinson Wright on

The Corporate Transparency Act (the “CTA” or the “Act”) has dropped off of most people’s radar, perhaps prematurely. Although December 2025 was not the CTA roller coaster that December 2024 was, it still provided some...more

Verrill

New York LLC Transparency Act Took Effect January 1 but Nearly All LLCs are Exempt

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When signed into law on March 1, 2024, the New York LLC Transparency Act (NYLTA) would have required Beneficial Ownership Disclosure (BOD) reports or Exemption Attestations from each and every limited liability company (LLC)...more

Rivkin Radler LLP

The Corporate Transparency Act: What Was Mostly Dead May Be Recovering?

Rivkin Radler LLP on

Near Death Experience - Stick a fork in it. It’s kaput. At least that’s what many of us thought; and, for all intents and purposes, it was. However, like a scene from a bad zombie movie, the corpse-like Corporate...more

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