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FinCEN Clarifies that Dissolved Entities are Subject to CTA Reporting Obligations

On July 8, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs with respect to the beneficial ownership reporting requirements of dissolved entities. The Corporate...more

U.S. District Court in Alabama Finds the Corporate Transparency Act Unconstitutional

On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (the “CTA”) is unconstitutional, leaving its future uncertain. The CTA requires...more

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other...more

CTA: FinCEN Clarifies Ownership Interests Must be Entirely Controlled or Wholly Owned to Qualify for the Subsidiary Exemption

On January 12, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs in response to questions received regarding compliance with various aspects of the Corporate...more

CTA – Accessing Beneficial Ownership Information

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

U.S. FinCEN Extends Timeframe for Reporting Companies Created in 2024 to File Beneficial Ownership Information Reports

Today, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule aimed to ease compliance with certain aspects of the regulations promulgated under the Corporate Transparency Act. The...more

Countdown to Transparency: Beneficial Ownership Reporting

In 2021, the U.S. enacted the Corporate Transparency Act (the “CTA”) as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the Treasury’s Financial...more

Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more

The Corporate Transparency Act – Government KYC

Summary of the Corporate Transparency Act under the National Defense Authorization Act for Fiscal Year 2021 - On January 1, 2021, the Corporate Transparency Act (the “CTA”), which is part of the National Defense...more

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