On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that exempts all domestic (US) companies from reporting under the Corporate Transparency Act (CTA). Non-U.S. companies that are...more
3/25/2025
/ Beneficial Owner ,
Corporate Transparency Act ,
Filing Deadlines ,
Final Rules ,
FinCEN ,
Foreign Corporations ,
Foreign Entities ,
Foreign Investment ,
Interim Final Rules (IFR) ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
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
3/5/2025
/ Corporate Transparency Act ,
Enforcement Actions ,
Financial Regulatory Reform ,
FinCEN ,
Foreign Investment ,
Penalties ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
U.S. Treasury
On February 27, 2025, FinCEN announced “that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI)...more
The Corporate Transparency Act’s reporting obligations are once again in force. For virtually all reporting companies, the new deadline to file an initial, updated and/or corrected beneficial ownership information (BOI)...more
On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more
2/10/2025
/ Appeals ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Filing Requirements ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 26, 2024, a merits panel of the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide injunction against enforcement of the Corporate Transparency Act (CTA) that had been entered by the United States...more
1/3/2025
/ Appeals ,
Commerce Clause ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Injunctions ,
Reporting Requirements ,
SCOTUS ,
Stays ,
Texas
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit entered an order that has the effect of again prohibiting the enforcement of the Corporate Transparency Act (CTA) and staying all CTA filing deadlines. A...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit entered an order that has the effect of reinstating Corporate Transparency Act (CTA) filing deadlines, including the upcoming deadline for certain entities...more
12/24/2024
/ Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, in Texas Top Cop Shop, Inc. v. Garland, Judge Mazzant of the U.S. District Court for the Eastern District of Texas, “determined that the CTA and Reporting Rule are likely unconstitutional for purposes of...more
12/5/2024
/ Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement ,
Financial Crimes ,
FinCEN ,
First Amendment ,
Fourth Amendment ,
Preliminary Injunctions ,
Reporting Requirements ,
Texas ,
Unconstitutional Condition
Background -
The Corporate Transparency Act of 2019 (“CTA”) became effective on January 1, 2024. Under the CTA, all “reporting companies” must file a Beneficial Ownership Information (BOI) report with the Financial Crimes...more
8/1/2024
/ Beneficial Owner ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Fines ,
Noncompliance ,
Penalties ,
Popular ,
Reporting Requirements ,
Sanctions
The Corporate Transparency Act (CTA), a law intended to enable the Financial Crimes Enforcement Network (FinCEN) to detect shell companies and protect the U.S. financial system from abuse by money launderers, drug...more
11/1/2023
/ Beneficial Owner ,
Corporate Counsel ,
Corporate Transparency Act ,
Data Breach ,
Data Protection ,
Data Security ,
Due Diligence ,
False Reporting ,
FinCEN ,
New Legislation ,
Reporting Requirements ,
Scams ,
Shell Corporations
The Financial Crimes Enforcement Network (“FinCEN”), a unit of the U.S. Treasury, is mandated with protecting the U.S. financial system from illicit use by making it more difficult for bad actors to conceal their financial...more