On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
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
3/3/2025
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
New Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Temporary Hold
Earlier this week, the Financial Crimes Enforcement Network (FinCEN) issued a new notice confirming that the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements are back in effect....more
As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the Corporate Transparency Act (CTA)...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays
The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more
9/23/2024
/ Annual Reports ,
Anti-Money Laundering ,
Bankruptcy Court ,
Bankruptcy Trustees ,
Beneficial Owner ,
Commercial Bankruptcy ,
Compliance ,
Deposit Accounts ,
FDIC ,
Financial Institutions ,
FinTech ,
Internal Controls ,
Investment ,
Misrepresentation ,
Non-Bank Lenders ,
Notice of Proposed Rulemaking (NOPR) ,
Policies and Procedures ,
Popular ,
Proposed Amendments ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Securities ,
Third-Party
The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more
8/23/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Compliance ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Popular ,
Risk Assessment ,
Risk Management
June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more
8/5/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Penalties ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On March 1, 2024, New York Governor Kathy Hochul signed an amended version of the New York LLC Transparency Act (NYLTA), which was originally signed with provisions for amendments in December 2023. The NYLTA will go into...more
As discussed in our prior Update on the Corporate Transparency Act (CTA), anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial...more
The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more
Key portions of the Corporate Transparency Act (CTA) will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the...more
12/11/2023
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more
12/5/2023
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Business Ownership ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Exemptions ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Reporting Requirements
The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more
Financial technology firms and certain banks and bank holding companies can expect to face increased scrutiny as the Board of Governors of the Federal Reserve System takes another step to stem risks related to crypto-assets,...more
President Biden issued a long-awaited executive order, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Executive Order or E.O.), on August 9, 2023,...more
8/17/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Compliance ,
Corporate Governance ,
Covered Person ,
Exceptions ,
Executive Orders ,
Foreign Direct Investment ,
Investment ,
Investors ,
National Security ,
Popular ,
Technology Sector ,
U.S. Treasury ,
White Collar Crimes
At 6:15 p.m. ET on March 12, 2023, the Department of the Treasury, Federal Reserve, and FDIC announced “actions enabling the FDIC to complete its resolution of Silicon Valley Bank, Santa Clara, California, in a manner that...more
3/13/2023
/ Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Crisis ,
Financial Institutions ,
Receivership ,
Silicon Valley ,
U.S. Treasury
Below is an overview of the failure of Silicon Valley Bank (SVB) and what we expect to happen next. This reflects information as of 4:00 p.m. PT on March 11, 2023. We note that it is an evolving situation; we will provide...more
3/13/2023
/ Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Crisis ,
Financial Institutions ,
Receivership ,
Silicon Valley ,
U.S. Treasury
Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more