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Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations

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

Federal District Court Finds Corporate Transparency Act Unconstitutional: What Now?

The CTA and Legal Challenges - The CTA is a sweeping new anti-money-laundering law that, as of January 1, 2024, requires most entities formed or registered to do business in the United States to disclose detailed...more

CTA Compliance Tip: Spouses and Domestic Partners in Community Property States May Also Be “Beneficial Owners”

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

Corporate Transparency Act Will Require Disclosure of Senior Officers and Directors of Many US and Foreign Companies

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

Think Public and Large Companies Are Entirely Exempt From the Corporate Transparency Act? Think Again.

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

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

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

FFIEC BSA/AML Exam Manual Updates - Implications for Banks

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

Mapping Future Enforcement in US Gaming Law Based on Recent UK Enforcement

Regulated gaming is booming in the United States. This is particularly true of newer forms of gambling, such as skill games, fantasy sports, and social casino games played on the internet and mobile applications. In fact,...more

FinCEN Issues Proposed Rule for Accessing Ownership Information Under the Corporate Transparency Act

The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more

FinCEN’s Highly Anticipated Beneficial Ownership Reporting Rule Under CTA Effective January 1, 2024

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more

Recent Developments in US Sanctions and Export Controls Targeting Russia

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

FinCEN Solicits Comments on Striking Expansion of Anti-Money Laundering Obligations to Real Estate Sector

The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) on December 6, 2021, soliciting comments on the potential extension of the Bank Secrecy Act (BSA), and the attendant...more

FinCEN Proposed Beneficial Ownership Rule

On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated proposed rule that would implement key provisions of the Corporate Transparency Act (CTA), a...more

AMLA 2020 Series Part 3: FinCEN Issues Notice of Proposed AML Rules for Antiquities Dealers

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

AMLA 2020 Series Part 1: New and Expansive Beneficial Ownership Reporting Requirements

As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more

The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways

On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more

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