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FinCEN Throws Another Curveball: Beneficial Ownership Reporting for Dissolved Companies

This week, FinCEN issued new FAQs interpreting the obligations of the Corporate Transparency Act (“CTA”) that would require entities that were dissolved prior to the due date of the beneficial ownership initial report (“BOI...more

FinCEN Proposes AML and SAR Filing Obligations for RIAs and ERAs

On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more

Updated FinCEN CTA Guidance Impacts Private Equity Funds

On January 12, 2024, FinCEN updated its interpretations of the Corporate Transparency Act (“CTA”) that potentially will have a significant impact on private equity firms. This alert provides an overview of the CTA and certain...more

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