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FinCEN › Reporting Requirements › Comment Period

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 -
Fenwick & West LLP

The Corporate Transparency Act: FinCEN Removes Reporting Reqs for US Companies and Persons, Sets New Deadlines for Foreign...

Fenwick & West LLP on

In a press release issued on March 21, 2025, FinCEN issued an interim final rule (IFR) revising the definition of “reporting company” to mean only those entities formed under the laws of a foreign country that have registered...more

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

Clark Hill PLC on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Montgomery McCracken

Corporate Transparency Act No Longer Applies to Entities Formed in the U.S.

Montgomery McCracken on

On March 26, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of the Treasury, published in the Federal Register an interim final rule that substantially narrows the...more

Seyfarth Shaw LLP

FinCEN Narrows Scope of Corporate Transparency Act

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On March 26, 2025, the Financial Crimes Enforcement Network’s (“FinCEN”) interim final rule (the “Interim Rule”) exempting domestic entities and U.S. persons from reporting beneficial ownership information (“BOI”) under the...more

Rivkin Radler LLP

Corporate Transparency Act Obligations for U.S. Companies Are No More

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After many years of ups and downs, legal challenges, injunctions and deadline changes, the reporting obligations under the Corporate Transparency Act (CTA) have disappeared…for most. On Friday, March 21, 2025, the Financial...more

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

McGlinchey Stafford on

Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Perkins Coie

Corporate Transparency Act: FinCEN Releases Interim Rule Limiting Application of CTA to Foreign Companies Registered to Do...

Perkins Coie on

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons

Keating Muething & Klekamp PLL on

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate...more

Bowditch & Dewey

Corporate Transparency Act – CTA for Foreign Reporting Companies Only

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On Friday, March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that eliminates reporting requirements for domestic reporting companies via redefining “reporting company” to include...more

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Morrison & Foerster LLP on

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

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As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Troutman Pepper Locke

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

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On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

McGlinchey Stafford

FinCEN Invites Comment on Final Beneficial Ownership Information Reporting Rule

McGlinchey Stafford on

On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice inviting comment on the Beneficial Ownership Information Reporting Requirements final rule (Final BOI Reporting Rule) that was...more

Orrick, Herrington & Sutcliffe LLP

FinCEN solicits feedback on beneficial ownership reporting requirements

Orrick, Herrington & Sutcliffe LLP on

On January 17, the Financial Crimes Enforcement Network (FinCEN) published two notices and requests for comment in the Federal Register related to the reporting process the agency intends to use to collect beneficial...more

Ballard Spahr LLP

FinCEN Requests Comment on Proposed Beneficial Ownership Reporting Form

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Form Repeatedly Invites Response of “Unknown” As to Critical Information - The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Saiber LLC

Advance Notice of Proposed Rulemaking Issued by FinCEN for Potential New Real Estate Sector Reporting Requirements

Saiber LLC on

On December 8, 2021, the Federal Crimes Enforcement Network (“FinCEN”) division of the United States Treasury published an Advance Notice of Proposed Rulemaking (“ANPRM”) (Anti-Money Laundering Regulations for Real Estate...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Holland & Knight LLP

FinCEN Announces Proposed Regulations for Sharing of Suspicious Activity Reports

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Troutman Pepper Locke

Some Key Takeaways From the FinCEN ‎December 7, 2021 Notice of Proposed Rule Making ‎Under the ‎Corporate Transparency Act

Troutman Pepper Locke on

As a follow-up to our earlier QuickStudies ‎on the Corporate Transparency Act (“CTA”), ‎Anti-‎Money Laundering Act of 2020 ("AMLA") and art and antiquities under the AMLA, we are providing this QuickStudy to highlight a few...more

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