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Reporting Requirements FinCEN Securities and Exchange Commission (SEC)

Fenwick & West LLP

SEC Outlines Disclosure Expectations for Offerings and Registrations of Securities in Crypto Asset Markets

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On April 10, 2025, the SEC’s Division of Corporation Finance (the Division) released a statement providing its views on disclosure requirements for Offerings and Registrations of Securities in the Crypto Asset Markets....more

Latham & Watkins LLP

SEC Staff Publishes Observations on Crypto Issuer Disclosures

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On April 10, 2025, the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance (the Staff) published a Statement on Offerings and Registrations of Securities in the Crypto Asset Markets (the Statement)....more

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

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As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

Akin Gump Strauss Hauer & Feld LLP

SEC Clears the Way for Crypto Custody

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

Morris, Manning & Martin, LLP

Securities & Corporate Governance Q4 2024 Quarterly Newsletter

Morris, Manning & Martin, LLP’s Securities & Corporate Governance Quarterly Newsletter is designed to update public and private company clients on recent developments in federal securities laws and corporate governance...more

Proskauer - Regulatory & Compliance

The Corporate Transparency Act: The Government Appeals Preliminary Injunction. What To Do Now?

The Corporate Transparency Act (CTA) requires all corporations, limited liability companies, limited partnerships, and many other entities created or registered to do business in any U.S. state to file a beneficial ownership...more

Holland & Knight LLP

A Look at the CTA's Subsidiary Exemption as Applied to CMBS Special Purpose Entities

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The Corporate Transparency Act (CTA) requires certain domestic and foreign entities, called "reporting companies," to file a beneficial ownership information (BOI) report – which provides information about their owners,...more

Wyrick Robbins Yates & Ponton LLP

The Corporate Transparency Act: A Reminder for Public Companies and Banks

On January 1, 2025, business entities in existence prior to January 1, 2024 must file initial beneficial ownership reports with the Financial Crimes Enforcement Network (“FinCEN”) under the federal Corporate Transparency Act....more

Proskauer Rose LLP

Deadline Approaches: FinCEN’s Rules for Beneficial Ownership Reporting under the Corporate Transparency Act

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The Corporate Transparency Act (the “CTA”) requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network...more

Cooley LLP

US Corporate Transparency Act Reporting Deadline Approaching – What You Need to Know

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Millions of existing companies formed or registered in the US on or before December 31, 2023, are required to file beneficial ownership information (BOI) reports on or before January 1, 2025, pursuant to the requirements of...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

Saul Ewing LLP

Public Companies Quarterly Update (Q2 2024)

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Welcome to Saul Ewing’s Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware. This edition is related to...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Are Entities in Your Private Fund Structure Reportable under FinCEN’s Beneficial Ownership Regulation?

As of January 1, 2024, the Beneficial Ownership Information Reporting Requirements (the “Reporting Rule”) issued by Financial Crimes Enforcement Network (“FinCEN”) to implement Section 6403 of the Corporate Transparency Act...more

White & Case LLP

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

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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

Jenner & Block

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

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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

Jenner & Block

Reporting Requirements under the Corporate Transparency Act

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The Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) issued final regulations under the Corporate Transparency Act (CTA) which, effective January 1, 2024, require most companies (i.e.,...more

BCLP

FinCEN Updates CTA FAQs for the First Time in Three Months - Includes Clarity About Reporting Requirements for Beneficial Owners

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On April 18, 2024, the Financial Crimes Enforcement Network (FinCEN) published an updated set of Frequently Asked Questions (FAQs) pertaining to the Beneficial Ownership Information (BOI) Reporting Rule under the Corporate...more

Partridge Snow & Hahn LLP

Recent Legal Developments Affecting Syndicated Real Estate Funds

Two recent developments may affect private funds, including syndicated real estate offerings.  First, at the end of last summer the SEC adopted the Private Fund Adviser rules, regulations that cover certain aspects of...more

WilmerHale

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

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On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...more

Jenner & Block

Client Alert: Unfinished Business: Investment Advisers Are Potentially Back on the Hook for Anti-Money-Laundering and...

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In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Mintz - Securities & Capital Markets...

New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Clients

Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA, many US entities will be required to provide the personal information of their beneficial owners to the...more

Sheppard Mullin Richter & Hampton LLP

The Corporate Transparency Act: A Reporting Guide for Medical Groups and MSOs

Congress passed the Corporate Transparency Act (the “CTA”) in 2021 with the aim of enhancing transparency in entity structures and ownership as well as combating terrorism, money laundering, and other forms of corporate...more

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