News & Analysis as of

FinCEN Civil Monetary Penalty

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

King & Spalding

Federal District Court in Alabama Declares CTA Unconstitutional; DOJ Appeals to 11th Circuit; FinCEN Requires Continued Compliance

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On March 1, 2024, a federal judge in the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA and its implementing regulations require that...more

Adams and Reese LLP

CTA Update – Where Do We Stand After Alabama District Court Ruling?

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On March 1, 2024, the Northern District of Alabama Northeastern Division, in National Small Business United v. Yellen, No. 5:22-cv-1448 (N.D. Ala.), ruled the Corporate Transparency Act unconstitutional. However, the holding...more

McNees Wallace & Nurick LLC

CTA Here to Stay? Federal District Court Rules Corporate Transparency Act Unconstitutional

Although the Corporate Transparency Act (“CTA”) became effective Jan. 1, 2024, in just two short months, its constitutionality was challenged in the U.S. District Court, Northern District of Alabama’s decision issued on March...more

Kohrman Jackson & Krantz LLP

Federal District Court in Alabama Deems Corporate Transparency Act Unconstitutional

The Corporate Transparency Act (the CTA), which became effective on January 1, 2024, was ruled unconstitutional by the U.S. District Court for the Northern District of Alabama (District Court), in the case styled National...more

Keating Muething & Klekamp PLL

FinCEN Issues Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements

On February 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a small entity compliance guide (the “Guide”) that provides an overview of the requirements regarding access to beneficial ownership...more

Foodman CPAs & Advisors

Cumplimiento/Ejecución BOI Para Empresas Que Reportan

Las empresas que reportan están obligadas a proporcionar información a FinCEN sobre las personas que en última instancia las poseen o las controlan. FinCEN comenzó a aceptar informes el 1 de enero de 2024. Las empresas que...more

Foodman CPAs & Advisors

BOI Compliance/Enforcement For Reporting Companies

Reporting companies are required to report information to FinCEN about the individuals who ultimately own or control them. FinCEN began accepting reports on January 1, 2024. Reporting Companies have a significant obligation...more

Morris, Manning & Martin, LLP

FinCEN Increases Civil Penalties Under the CTA

Last week, the Financial Crimes Enforcement Network (FinCEN) released a final rule modifying specific maximum civil penalties within its jurisdiction. These increases are routine changes to improve the effectiveness of civil...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Warner Norcross + Judd

New Corporate Transparency Act Reporting Requirement Begins in 2024

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Starting in 2024, all “reporting companies,” meaning any entity formed by filing with a secretary of state or similar office, will be required to file a “beneficial ownership report” with the U.S. Treasury Department’s...more

Fox Rothschild LLP

New Mandatory Reporting for Vast Majority of Businesses Starts in January 2024

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In less than two weeks, on January 1, 2024, the Corporate Transparency Act (CTA) will become effective. This new law is one of the most wide-reaching and disruptive pieces of legislation affecting businesses that has been...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Hinshaw & Culbertson LLP

REMINDER: New Federal Corporate Transparency Act Set to Impose Significant New Reporting Requirements and Noncompliance Penalties...

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As we approach year-end, we wanted to remind you about the upcoming implementation of the Corporate Transparency Act ("CTA"), which is set to take effect on January 1, 2024. The CTA will impose significant new reporting...more

Dunlap Bennett & Ludwig PLLC

Corporate Transparency Act Requires Small Businesses To Disclose Beneficial Ownership Information Beginning In 2024

In January of 2021, Congress passed the Corporate Transparency Act of 2019 (the “CTA”) as part of the 2021 Defense Bill. Initially introduced in 2019, the CTA requires private companies to disclose their “Beneficial Owners”...more

Levenfeld Pearlstein, LLC

The Corporate Transparency Act Takes Effect January 1, 2024 – What to Know and How to Report

The new Corporate Transparency Act (“CTA”) takes effect January 1, 2024, creating reporting obligations for most business entities, including corporations, limited liabilities companies, and other entities formed by filing...more

Perkins Coie

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

Perkins Coie on

Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

Saiber LLC

The Corporate Transparency Act: Are You Prepared?

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Beginning on January 1, 2024, millions of business entities (including corporations, limited liability companies, and other similar entities created in or registered to do business in the United States) will be required to...more

Procopio, Cory, Hargreaves & Savitch LLP

Decoding the Corporate Transparency Act: Navigating the Changes Ahead

The reporting requirements for beneficial ownership information under the Corporate Transparency Act (CTA) will come into effect on January 1st, 2024. The CTA, a bipartisan law enacted by Congress on January 1st, 2021,...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Pillsbury Winthrop Shaw Pittman LLP

The Corporate Transparency Act: Beneficial Ownership Information Reporting Checklist

The Corporate Transparency Act requires a broad range of entities to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) identifying those who own, control and formed the...more

Dechert LLP

A New Risk Calculus: U.S. Department of Commerce Raises Stakes for Failing to Voluntarily Self-Disclose Potential Export Controls...

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On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Assistant Secretary for Export Enforcement, Matthew Axelrod, published a memorandum marking a shift in policy regarding voluntary...more

Goodwin

FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers

Goodwin on

Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update – FinCEN Issues Notice of Proposed Rulemaking

On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues final rule replacing obsolete BSA civil penalty regulations

On December 23, the Financial Crimes Enforcement Network (FinCEN) published a final rule amending the Bank Secrecy Act civil penalty regulations concerning requirements for reporting foreign financial accounts and...more

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