Too Big To Fail in the Dodd-Frank Era
The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more
In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (NPRM or “Proposed Rule”) to implement the beneficial ownership information (BOI) reporting provisions of the...more
The government has unveiled an ambitious series of reforms to Companies House in what it describes as “the largest change to our system of setting up and operating companies since the register was created in 1844.” These...more
The Financial Action Task Force has issued a detailed report on the concealment of beneficial ownership, assessing how legal persons, legal arrangements and professional intermediaries can help criminals conceal wealth and...more