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Rulemaking Process Reporting Requirements Enforcement Actions

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

Brooks Pierce on

Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Warner Norcross + Judd

CTA Filing is Now Voluntary for US Entities and Citizens: Rule Changes Ahead

Warner Norcross + Judd on

The United States Treasury Department announced on March 2, 2025, that the Beneficial Ownership Information (BOI) reporting required by the Corporate Transparency Act (CTA) is now voluntary for U.S. entities and citizens....more

Downs Rachlin Martin PLLC

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

The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their...more

Katten Muchin Rosenman LLP

US Treasury Announces That the Corporate Transparency Act Will Not Be Enforced Against Domestic Companies, Their Beneficial Owners...

As noted in our previous Corporate Advisory, the Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025, that it will not take enforcement action against a Reporting Company that fails to file or update...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure CTA Updates — March 2025

FinCEN announced on February 27, 2025, that it will not impose fines or penalties for failures to file or update beneficial ownership information (BOI) reports in connection with the Corporate Transparency Act by the current...more

Seward & Kissel LLP

Treasury Department Confirms: No Fines or Penalties in Connection with BOI Reporting Deadlines

Seward & Kissel LLP on

While the March 21, 2025 filing deadline under the Corporate Transparency Act (the “CTA”) remains in place, the Treasury Department announced on March 2nd that it will not enforce any penalties or fines associated with...more

Whiteford

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

Whiteford on

On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Ballard Spahr LLP

Department of the Treasury Suspends Enforcement of the Corporate Transparency Act and Plans to Revise Rule to Limit Scope

Ballard Spahr LLP on

Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”)....more

Neal, Gerber & Eisenberg LLP

Treasury Limits CTA Enforcement to Foreign Companies

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

Wiley Rein LLP

Treasury Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

Wiley Rein LLP on

Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking - On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more

Foley & Lardner LLP

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

Foley & Lardner LLP on

The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

Perkins Coie

Corporate Transparency Act: Treasury Announces No Enforcement for Reporting Failures by U.S. Citizens and Domestic Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Husch Blackwell LLP

U.S. Treasury Department Declines to Enforce CTA

Husch Blackwell LLP on

On March 2, 2025, the U.S. Department of the Treasury ended months of speculation regarding how the Corporate Transparency Act (CTA) would be implemented and enforced under the second Trump administration. Via press release,...more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

Snell & Wilmer on

In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

Pierce Atwood LLP

Out With a Bang: Treasury Restricts Corporate Transparency Act to Foreign Reporting Companies

Pierce Atwood LLP on

On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens....more

Shipkevich PLLC

U.S. Treasury Department Announces Suspension of BOI Reporting Penalties for U.S. Parties

Shipkevich PLLC on

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that most reporting companies under the Corporate Transparency Act (“CTA”) must now submit their Beneficial Ownership Information (“BOI”)...more

Foley Hoag LLP

FinCEN Pauses Enforcement of Corporate Transparency Act (Again!)

Foley Hoag LLP on

FinCEN has once again changed course on enforcement of the CTA. On February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against reporting companies based on a...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

Paul Hastings LLP on

On December 19, 2024, the Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) intended to “update and clarify” the regulations under the Foreign Agents Registration Act (FARA). The proposed changes to...more

Proskauer Rose LLP

FTC Announces 2025 Thresholds Under HSR Act and Clayton Act

Proskauer Rose LLP on

Primary HSR Filing Threshold will be Increased to $126.4 Million - The Federal Trade Commission has announced revisions to HSR Act and Clayton Act Section 8 thresholds, which are indexed annually in alignment with prior...more

WilmerHale

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

WilmerHale on

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

DarrowEverett LLP

Actions vs. J.P. Morgan, Monolith Serve as SEC Compliance Check Reminders

DarrowEverett LLP on

The Securities and Exchange Commission (SEC) recently settled charges against J.P. Morgan Securities LLC (JPMS) for impeding hundreds of advisory clients and brokerage customers from reporting potential securities law...more

Proskauer Rose LLP

SEC Adopts Amendments to Rule 10b5-1 and Related Disclosure Requirements

Proskauer Rose LLP on

On December 14, 2022, the SEC adopted amendments to Rule 10b5-1 under the Securities Exchange Act of 1934 and added related new disclosure requirements. Rule 10b5-1 provides an affirmative defense to insider trading liability...more

Foley & Lardner LLP

Private Funds in the Hot Seat under Gensler's SEC

Foley & Lardner LLP on

Since Chair Gary Gensler’s nomination in February, the securities industry has speculated on the rulemaking and enforcement priorities of the Securities and Exchange Commission (“SEC”) under his oversight. While Gensler has...more

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