On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”) requiring reports by “reporting persons” concerning real estate transfers to a legal entity or trust of certain...more
As reported in our earlier QuickStudies on the Corporate Transparency Act (the “CTA”) and the Regulations adopted by the Financial Crimes Enforcement Network (“FinCEN”), each company in existence on or after January 1, 2024...more
On December 21, 2024, amendments to the New York Limited Liability Company Law will take effect requiring domestic New York LLCs and foreign LLCs qualified to do business in New York to disclose information concerning their...more
Public Companies are Exempt, But . . .
Public companies have an exemption from the filing requirements under the new Corporate Transparency Act (CTA) reporting rules. The public company exemption applies to companies that...more
As of January 1, 2024 (the “Effective Date”), many domestic and foreign entities formed or registered by a filing with a Secretary of State or comparable office in a State, the District of Columbia or a tribal authority (a...more
The Financial Crimes Enforcement Network (FinCEN), a part of the U.S. Treasury Department, amended the regulations under the Corporate Transparency Act (CTA) to extend the 30 day deadline to 90 days from the date of formation...more
The Corporate Transparency Act (“CTA”), which goes into effect on January 1, 2024, requires filings with the Financial Crimes Enforcement Network (“FinCEN”) (part of the U.S. Department of the Treasury) by most newly formed...more
FinCEN, a part of the U.S. Department of the Treasury, issued its Small Business Compliance Guide (the “Guide”) to assist companies and their managements and advisors to meet their filing requirements under the Corporate...more
Final regulations were adopted on September 29, 2022 by the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of Treasury (the “Beneficial Ownership Rule” or the “Rule”) under the Corporate Transparency...more
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
On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) under the Corporate Transparency Act (the “CTA”). The CTA went into effect January 2, 2020 and...more
On September 23, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) soliciting public comment on possible rules implementing Section 6110 of the Anti-Money...more
The Anti-Money Laundering Act of 2020 (the “AMLA”), which became law January 2, 2021 with Congress’ override of then President Trump’s veto of the Defense Appropriations Act of 2021 included provisions bringing dealers in...more
The House of Representatives and the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). The NDAA includes the Anti-Money Laundering Act of 2020 (“AMLA”)...more
On January 13, 2016, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two temporary Geographic Targeting Orders (the Orders) that will require title insurance companies to identify...more