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FinCEN Eliminates CTA Compliance for U.S. Corporate Entities and U.S. Persons – Limiting Compliance to Foreign Reporting Companies

On Friday, March 21, 2025, the United States Financial Crimes Enforcement Network (“FinCEN”) issued for publication in the Federal Register an “interim final rule” (the “Revised Rule”) that effectively exempts all domestic...more

U.S. Treasury Abandons the CTA For All Entities Except “Foreign Reporting Companies”

As we previously announced, last week FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for...more

FinCEN Halts Enforcement of CTA (again!) - A Promised Future Rulemaking Will Reset Compliance Obligations

Having only announced its extended March 21, 2025 deadline to file beneficial ownership information reports under the Corporate Transparency Act (“CTA”) last week, on February 27, 2025, FinCEN confirmed that it would “not...more

FinCEN Confirms New CTA Filing Deadline - But Congress Looks to Push Deadlines For Some Reporting Entities to 2026

On February 18, 2025, in a widely expected decision, the Eastern District of Texas, in the case of Smith v. United States Dep't of the Treasury, 2025 WL 41924 (E.D. Tex.), and following the decision of the U.S. Supreme Court...more

Predictions for the Federal Financial Service Agencies - Slow Down and Wait

Following the myriad nominations, acting appointments and Executive Orders by the new Administration, many clients and friends have requested advice regarding legal and regulatory changes that might be forthcoming in the...more

U.S. Government Appeals CTA Injunction - But Changes to Reporting Requirements May Be On The Horizon

As we previously reported, on January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to...more

SCOTUS Overturns One CTA Nationwide Injunction - but Reporting Requirements Still Paused…

On January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to overturn the nationwide...more

CTA Compliance Paused Yet Again - Federal Appeals Court Reinstates Temporary Nationwide Injunction

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Texas Top Cop...more

FinCEN Sets Revised CTA Filing Deadlines After Federal Appeals Court Overrules Temporary Nationwide Injunction

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the government’s emergency motion and stayed the temporary nationwide injunction that prohibited enforcement of the Corporate Transparency...more

FinCEN Responds to Temporary Injunction Halting Enforcement of the Corporate Transparency Act

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against 31 U.S.C. § 5336 and the enforcement of the beneficial ownership information reporting rule...more

Department of Justice Appeals Temporary Injunction Halting Enforcement of the Corporate Transparency Act

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against 31 U.S.C. § 5336 and the enforcement of the beneficial ownership information reporting rule...more

CTA Compliance Obligations for CTA Participants: Reporting Companies, Beneficial Owners, and Third-Party Preparers

In an evolving (and somewhat disjointed) process, FinCEN has been providing guidance to persons and entities that are responsible for filing required beneficial ownership information (“BOI”) reports to FinCEN, as well as to...more

FinCEN’s Final Regulations to Implement the Corporate Transparency Act

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

FinCEN Issues Final Regulations to Implement the BSA’s Revised Beneficial Ownership Requirements

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

Crypto Assets: From Off The Grid To A Seat At The Table

The Beginning - Crypto assets were initially “off the grid,” and many early proponents celebrated the promise of their regulatory independence. While conventional assets were governed by a virtual alphabet soup of federal...more

FinCEN Urges Financial Institutions to Guard Against Attempts to Evade Sanctions

On March 7, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “FinCEN Alert”) urging financial institutions to proactively guard against possible attempts to evade recently implemented sanctions...more

FinCEN Proposes Regulations to Implement the BSA’s Revised Legal Entity Requirements

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on December 8, 2021, the Financial Crimes Enforcement...more

The Prudential Bank Regulators Adopt Federal Data Interruption Notice Requirements for FDIC-Insured Institutions and Service...

On November 23, 2021, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Federal Reserve Board (the “Prudential Regulators”) exercised their collective...more

Termination of U.S. LIBOR Tenors Postponed Until June 30, 2023

On November 30, 2020, the ICE Benchmark Administration Limited (commonly referred to as “ICE”) announced its plan to extend the date that most U.S. LIBOR values would cease being computed and announced from December 31, 2021...more

The OCC’s CRA Regulatory Reboot

Immediately prior to his departure as the Comptroller of the Currency , Joseph Otting finalized the OCC’s restructuring of its version of the Community Reinvestment Act’s implementing regulations (the “CRA Amendments”) -...more

Potential Issues for Warehouse Providers with Electronic Mortgage Notes

Fannie Mae and Freddie Mac (the “GSEs”), working together with Mortgage Electronic Registry Systems (“MERS”), have been promoting the use of electronic mortgage notes (“eNotes”) in the residential mortgage industry. MERS,...more

California Attorney General Issues Draft Regulations for CCPA

On October 11, 2019, the California Attorney General (the “California AG”) issued draft regulations (the “Draft Regulations”) pursuant to his authority under the California Consumer Privacy Act of 2018 (“CCPA”). The...more

House Harvests Increase in Farmer Eligibility for Bankruptcy – Senate Sows Seeds to Match

On July 26, 2019, the U.S. House of Representatives passed H.R. 2336, the Family Farmer Relief Act of 2019.  The primary purpose of the bill, sponsored by Rep. Anthony Delgado (D-NY), is to increase the debt limit for filing...more

National Financial Institutions - Developing A Project Plan To Comply With The California Consumer Privacy Act

Since its adoption last year, U.S. financial institutions have been confronted with the challenge of planning their compliance with the California Consumer Privacy Act (the “CCPA”). The CCPA becomes effective in two stages -...more

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