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FinCEN Requires Reporting from Dissolved Companies

On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance that requires certain legal entities that have been dissolved or otherwise ceased to exist to file beneficial ownership...more

FinCEN Requires Reporting from Dissolved Companies

On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance explaining that the beneficial ownership information (“BOI”) reporting requirement applies to certain legal entities that have...more

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

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