News & Analysis as of

Filing Requirements Reporting Requirements Compliance

Walkers

Update on the beneficial ownership reporting regime in the Cayman Islands - ongoing obligations and developments

Walkers on

Entities have ongoing obligations to keep beneficial ownership information up to date. Legislative developments have clarified what information needs to be reported for trusts and deemed beneficial owners....more

Hinshaw & Culbertson LLP

FinCEN Confirms U.S. Companies and U.S. Persons are Exempt from CTA Compliance

In a significant development, the Financial Crimes Enforcement Network (FinCEN) recently issued an interim final rule (the IFR) that dramatically changes who is subject to the Corporate Transparency Act (CTA) and its...more

Wyrick Robbins Yates & Ponton LLP

FinCEN Issues Revised Corporate Transparency Act Rule; Domestic Companies Exempt

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule under the Corporate Transparency Act. The revised rule changes the definition of “reporting company” to mean any entity that...more

Akin Gump Strauss Hauer & Feld LLP

SEC Staff Issues Guidance on Effectiveness of Form S-3 After Filing Form 10-K but Prior to Filing Part III Information

On March 20, 2025, the U.S. Securities and Exchange Commission (SEC) staff issued a set of Compliance & Disclosure Interpretations (C&DIs). In particular, SEC staff revised or withdrew several C&DIs to allow all Form S-3s,...more

Buchalter

2025 Filing Requirements and Contribution Limits for California “Major Donors”

Buchalter on

Individuals and business or nonprofit entities–such as corporations, partnerships and LLCs– that do not receive political contributions (i.e., do not have a PAC), but only make such contributions to California state and...more

Mayer Brown Free Writings + Perspectives

Prepare for “EDGAR Next” – Transition Begins March 24, 2025; SEC Guidance Available

On March 6, 2025, the Securities and Exchange Commission (“SEC”) issued a press release relating to the enhanced Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system (“EDGAR Next”), including useful links to...more

Mayer Brown

Whiplash: FinCEN Reverses Course, Delays CTA Enforcement Once Again

Mayer Brown on

On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more

Cooley LLP

EDGAR Next begins March 24

Cooley LLP on

In this new press release, Filer Transition to New and Improved EDGAR Begins March 24, the SEC provides references and links to “extensive guidance and resources” available to assist filers with EDGAR Next. According to the...more

Saul Ewing LLP

U.S. Treasury Announces It Will Not Enforce the Corporate Transparency Act Against U.S. Companies and Citizens

Saul Ewing LLP on

​On March 1, 2025, the U.S. Department of the Treasury announced that it will not enforce the Corporate Transparency Act (CTA) against U.S. citizens or domestic reporting companies or their beneficial owners. Treasury also...more

Tonkon Torp LLP

The Corporate Transparency Act – Penalties Suspended

Tonkon Torp LLP on

The Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement action for failing to file or update BOI reports by the current...more

Polsinelli

Important Update – Treasury Will Not Enforce CTA Against U.S. Citizens, Domestic Reporting Companies and Their Beneficial Owners –...

Polsinelli on

The U.S. Department of the Treasury announced on Sunday March 2, 2025 that it will “not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners [ …]” This press release...more

Cadwalader, Wickersham & Taft LLP

U.S. Treasury Department Suspends Enforcement of Corporate Transparency Act Against Domestic Reporting Companies and U.S....

On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more

Hinshaw & Culbertson LLP

UPDATE: U.S. Department of the Treasury Terminates Enforcement of the Corporate Transparency Act Against U.S. Citizens and...

U.S. citizens and domestic companies will no longer be subject to the CTA or its reporting requirements. Just under two weeks after the Financial Crimes Enforcement Network (FinCEN), an enforcement bureau within the U.S....more

Offit Kurman

An Update on Federal and Pennsylvania Corporate Reporting Requirements

Offit Kurman on

Much confusion has surrounded the Federal Corporate Transparency Act and the new Pennsylvania annual reporting requirement. Many have asked: what is the status (and deadlines) for compliance? The Federal Corporate...more

Stinson LLP

CTA Effectively Paused: No Enforcement Actions Until FinCEN Issues New Interim Final Rule and Revised Reporting Deadlines

Stinson LLP on

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury announced that it will not be issuing any fines or penalties or taking any other enforcement actions against any...more

Burr & Forman

Corporate Transparency Act Enforcement Suspended for U.S. Citizens and U.S. Entities

Burr & Forman on

What Happened? On February 18, 2025, the last of the nationwide injunctions enjoining enforcement of the Corporate Transparency Act (“CTA”), Smith, et al. v. U.S. Department of the Treasury, et al., (E.D. Tex.), was stayed,...more

Bilzin Sumberg

Treasury Department and FinCEN Announce Drastic Limits on Enforcement of Corporate Transparency Act

Bilzin Sumberg on

In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more

Polsinelli

Important Update - FinCEN Currently Not Issuing Fines or Penalties in Connection with CTA Reporting Deadlines (February 27, 2025...

Polsinelli on

On February 27, 2025, FinCEN issued a release providing that “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership...more

Pierce Atwood LLP

Out With a Bang: Treasury Restricts Corporate Transparency Act to Foreign Reporting Companies

Pierce Atwood LLP on

On March 2, 2025, the 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....more

Lowndes

Corporate Transparency Act Will Not Be Enforced Against U.S. Citizens and Entities

Lowndes on

In a press release issued on March 2, 2025, the United States Department of the Treasury announced that “with respect to the Corporate Transparency Act…[it will] not enforce any penalties or fines against U.S. citizens or...more

Vorys, Sater, Seymour and Pease LLP

Corporate Transparency Act Deadlines Extended

On February 27, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a release announcing that it intends to issue an interim final rule by March 21, 2025 that will extend the current deadlines to file or...more

Hinshaw & Culbertson LLP

UPDATE: FinCEN Pauses Penalties for CTA Reporting Noncompliance and Signals Additional Changes

As discussed in our previous alert, in connection with the recent reinstatement of the Corporate Transparency Act (CTA) and its reporting obligations, FinCEN issued an announcement (the "Prior Announcement") extending the...more

Morris, Manning & Martin, LLP

Treasury Department Ends its Enforcement of CTA, But Compliance Risks Remain

On March 2, 2025, the U.S. Treasury Department issued a press release announcing that, for now, the Department will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under...more

Cadwalader, Wickersham & Taft LLP

SEC Staff Issues New Guidance Regarding Schedule 13D/G

On February 11, 2025, the SEC staff published updates to two Compliance and Disclosure Interpretations (C&DIs) regarding the availability of Schedule 13G to certain investors, specifically concerning activities that could...more

K&L Gates LLP

EDGAR Next: The Next Era in Filing

K&L Gates LLP on

Introduction - On 27 September 2024, the Securities and Exchange Commission (SEC) adopted “EDGAR Next,” a collection of rule and form amendments intended to improve access to, and management of, accounts on the SEC’s filing...more

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