News & Analysis as of June 2, 2025

Financial Regulatory Reform

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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 -

FinCEN Eliminates BOI Reporting for U.S. Companies under the Corporate Transparency Act

Pullman & Comley, LLC on 3/25/2025

On March 21, 2025 FinCEN published an interim final rule that eliminates “beneficial ownership information” (BOI) reporting requirements for all domestic companies. ...more

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

Woods Rogers on 3/24/2025

Consistent with the Treasury Department’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule on March 21, 2025 that removes the requirement for U.S. companies and U.S....more

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

Buchalter on 3/14/2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

FINCEN Filings Terminated

Lasher Holzapfel Sperry & Ebberson PLLC on 3/11/2025

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

Weintraub Tobin on 3/7/2025

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

Treasury Limits CTA Enforcement to Foreign Companies

Neal, Gerber & Eisenberg LLP on 3/5/2025

On March 2, 2025, the Treasury Department expanded the scope of FinCEN’s February 27, 2025 statement that it will not enforce any penalties or fines under the Corporate Transparency Act with respect to existing regulatory...more

CTA Is In Effect, For Now

Cole Schotz on 2/20/2025

As of today, the Corporate Transparency Act (the “CTA”) is back in effect, with the deadline to file Beneficial Ownership Information (“BOI”) extended to March 21, 2025 for those entities that are not exempt from filing....more

SEC Clears the Way for Crypto Custody

Akin Gump Strauss Hauer & Feld LLP on 1/24/2025

On January 23, 2025, barely 72 hours after the appointment of Mark Uyeda as the Acting Chairman of the U.S. Securities and Exchange Commission, and less than 48 hours after Chairman Uyeda announced that Commissioner Hester...more

GLI British Virgin Islands blockchain and cryptocurrency regulation 2025, seventh edition

Carey Olsen on 1/8/2025

Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

Breaking News: Fifth Circuit Court of Appeals Stays Nationwide Preliminary Injunction Enjoining Enforcement of the Corporate...

Katten Muchin Rosenman LLP on 12/24/2024

Update: As of December 23, 2024, and until FinCEN issues updated guidance, the CTA reporting deadlines remain in effect (including January 1, 2025, for non-exempt Reporting Companies created prior to January 1, 2024)....more

Client Alert: FinCEN's Formal Position on the Corporate Transparency Act Nationwide Injunction

Shumaker, Loop & Kendrick, LLP on 12/11/2024

On December 9, the Financial Crimes Enforcement Network (FinCEN) released its official position on the preliminary injunction of the Corporate Transparency Act (CTA), issued on December 3, 2024, by the U.S. District Court of...more

Corporate Transparency Act: Texas Injunction Stays Enforcement of CTA

Brooks Pierce on 12/5/2024

On Tuesday, December 3, 2024, a United States district court in the Eastern District of Texas issued a national preliminary injunction enjoining the enforcement of the Corporate Transparency Act. The injunction specifically...more

Breaking News: Federal District Court Halts Corporate Transparency Act Enforcement Nationwide

Katten Muchin Rosenman LLP on 12/5/2024

This Corporate Advisory provides a brief update on recent litigation regarding the Corporate Transparency Act (CTA) and its reporting requirements. It is not intended to, and does not, provide legal, compliance or other...more

Corporate Transparency Act’s January 1, 2025, Deadline Looms for Reporting Companies Existing Prior to 2024

Epstein Becker & Green on 11/26/2024

The reporting requirements of the Corporate Transparency Act (CTA), included as part of the Anti-Money Laundering Act of 2020, went into effect on January 1, 2024, and certain deadlines of January 1, 2025, are fast...more

Filing a BOI Report Online: A Step-by-Step Guide

Verrill on 10/29/2024

Navigating the process of filing Beneficial Ownership Information (BOI) reports can be challenging. That's why we've created a comprehensive guide to help you through the technical steps of completing your online BOI...more

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

Seyfarth Shaw LLP on 10/11/2024

On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Corporate Transparency Act Filing Deadlines Approaching - What You Need to Know, Part I

Burr & Forman on 10/9/2024

The Corporate Transparency Act (CTA) requires “reporting companies” to report certain beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in order to enhance...more

Important Filing Deadline: The U.S. Corporate Transparency Act

Wilson Sonsini Goodrich & Rosati on 10/8/2024

As we approach the final quarter of 2024, we wanted to remind you of the rapidly approaching deadline for the new Beneficial Ownership Information (BOI) reporting requirements under the U.S. Corporate Transparency Act (CTA)....more

Navigating the Complexities of CTA Compliance: What You Need to Know

Stradling Yocca Carlson & Rauth on 9/26/2024

On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule to implement beneficial ownership reporting requirements set forth in the Corporate Transparency Act (the “CTA”). The CTA...more

The Final Countdown: Major CTA Reporting Deadline Rapidly Approaching

Stinson LLP on 9/11/2024

Barring any unforeseen changes, the Corporate Transparency Act's (CTA) major reporting deadline arrives on January 1, 2025. The CTA requires all existing reporting companies (those entities formed prior to January 1, 2024) to...more

FinCEN Clarifies Application of Beneficial Ownership Reporting Rules to Dissolved Entities

Jones Day on 8/27/2024

Reporting companies should take note of a recent clarification by the Financial Crimes Enforcement Network ("FinCEN") that the Beneficial Ownership Information ("BOI") Rule requires reporting companies that exist on or after...more

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

Ballard Spahr LLP on 8/5/2024

The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Entities That 'Cease to Exist' Must Still Comply With the Corporate Transparency Act

Faegre Drinker Biddle & Reath LLP on 7/23/2024

On Monday, July 8, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released additional FAQs specifying that a reporting company (i.e., a company to which no exemption applies) created or...more

Recent Developments & Challenges to the Corporate Transparency Act

Kohrman Jackson & Krantz LLP on 6/10/2024

As we continue to monitor the future of the Federal Corporate Transparency Act (the CTA), which requires certain businesses to file a report disclosing their beneficial owners to the U.S. government, new developments in both...more

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

Jenner & Block on 5/20/2024

In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

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