In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current...more
The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from...more
After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate...more
The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court...more
In our last update, we reported that despite the Supreme Court staying the nationwide injunction against FinCEN’s enforcement of the CTA in one Texas case, a nationwide stay of the Reporting Rule granted by a federal judge in...more
2/20/2025
/ Appeals ,
Beneficial Owner ,
Corporate Transparency Act ,
Enforcement Actions ,
FinCEN ,
Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
SCOTUS ,
Texas ,
Vacated
Here we go again – another CTA update hot off the press.
In our last update, we reported that the U.S. Department of Justice (DOJ) filed with the U.S. Supreme Court an emergency application to stay the injunction...more
Another flurry of court activity has further muddied the Corporate Transparency Act (CTA) waters, leaving additional uncertainty about its enforceability.
You may recall that on December 26, 2024, the Fifth Circuit...more
A flurry of activity in the Fifth Circuit this holiday season left clients asking the same questions about the Corporate Transparency Act (CTA): “Do we report Beneficial Ownership Information?” “If so, when is the...more
Just what you wanted – another holiday edition of Subject to Inquiry tracking the legal wrangling around the Corporate Transparency Act (CTA). If you’ve just joined our program...more
On Dec. 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted the government’s emergency motion for a stay of a District Court’s nationwide preliminary injunction against enforcement of the Corporate Transparency...more
On December 3, 2024, the United States District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Enacted as part of the...more
As 2024 comes to a close, companies created prior to January 1, 2024 should be mindful of the year-end deadline to analyze whether they must report Beneficial Ownership Information (“BOI”) to the U.S. Department of Treasury’s...more
On May 6, 2024, the Financial Crimes Enforcement Network (“FinCEN”) Director Andrea Gacki, Acting Chief of the Enforcement Division Steve Hsieh, Acting Associate Director of the Policy Division James Martinelli, and other key...more
On March 1, 2024, the United States District Court for the Northern District of Alabama declared the Corporate Transparency Act (“CTA”) unconstitutional. Enacted as part of the Anti-Money Laundering Act of 2020, the CTA...more
Rule Regarding Access to Beneficial Ownership Information Takes Effect -
On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency Act’s (“CTA”) Beneficial...more
On December 23, 2023, New York Governor Kathy Hochul signed the New York LLC Transparency Act (“NYLTA”), which requires LLCs to disclose beneficial ownership information (“BOI”) to the New York Department of State. Effective...more
As of January 1, 2024, the Corporate Transparency Act (“CTA”) has gone into effect. Companies that may be Reporting Companies of Beneficial Ownership Information (“BOI”) should be aware of three key aspects of the CTA....more
The Corporate Transparency Act (“CTA”) was enacted in 2021 as part of the Anti-Money Laundering Act of 2020. The CTA requires certain business entities (“Reporting Companies”) to report beneficial ownership information...more
The Corporate Transparency Act (“CTA”) was enacted in 2021 as part of the Anti-Money Laundering Act of 2020, requiring certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”), and,...more
Corporate Transparency Act Beneficial Ownership Reporting Requirements to Take Effect -
In 2021, the Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020, requiring certain...more
The Department of Justice Criminal Division announced a “Pilot Program Regarding Compensation Incentives and Clawbacks” (the “Program”) this week with broad implications for corporations and their individual executives...more
At long last, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule establishing a beneficial ownership information reporting requirement for corporations and companies both large and small. In its...more
On January 25, 2022, the Financial Crimes Enforcement Network (“FinCEN”) solicited commentary regarding its proposed rule that would create a time-limited pilot program to expand the ability of financial institutions to share...more
On December 10, 2020, FinCEN Director Kenneth Blanco delivered prepared remarks at the ABA’s annual Financial Crimes Enforcement Conference. At the outset, Director Blanco addressed the importance of U.S. national security...more
On September 15, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a Final Rule bringing banks that lack a federal functional regulator further under its purview. The rule subjects these institutions to...more