News & Analysis as of

Filing Requirements Constitutional Challenges Enforcement Actions

Eversheds Sutherland (US) LLP

FinCEN Southwest border GTO challenged by Texas trade group

On April 1, 2025, the Texas Association for Money Service Businesses filed a lawsuit in San Antonio federal court challenging the recent Geographic Targeting Order (GTO) applicable to money services businesses (MSBs) located...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

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

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

Pierce Atwood LLP on

On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...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

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

Foley Hoag LLP

Corporate Transparency Act Remains Subject to Nationwide Preliminary Injunction Despite Supreme Court Ruling

Foley Hoag LLP on

On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction of the Corporate Transparency Act (“CTA”) previously issued by the U.S. Federal District Court for the Eastern District of Texas (Texas...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

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

Cole Schotz on

Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Rivkin Radler LLP

SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause

Rivkin Radler LLP on

The Financial Crimes Enforcement Network (“FinCEN”) announced on Friday, January 24, 2025, that reporting companies are not currently required to file beneficial ownership information (“BOI”) under the Corporate Transparency...more

Proskauer Rose LLP

2016 Proskauer Annual Review and Outlook for Hedge Funds, Private Equity Funds and Other Private Funds

Proskauer Rose LLP on

This special report provides a summary of some of the significant changes and developments that occurred in the past year in the private equity and hedge funds space, as well as certain recommended practices that investment...more

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