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Corporate Transparency Act Litigation Update:  Eleventh Circuit Hears Argument, and District of Oregon Rejects Preliminary...

Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted...more

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

Final CTA Access Rule Answers Some Questions, and Leaves Open Others

The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog...more

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more

FinCEN Publishes Initial Guidance and FAQs on BOI Reporting Under CTA While Facing Backlash Over Proposed Access Rules and...

On March 24, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a press release and published initial guidance to assist the public in understanding the beneficial ownership information (BOI) reporting...more

FinCEN Requests Comment on Proposed Beneficial Ownership Reporting Form

Form Repeatedly Invites Response of “Unknown” As to Critical Information - The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more

Proposed Beneficial Ownership Reporting Regulations Under the CTA:  Broad and Complex

As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more

FinCEN Issues First Notice of Proposed Rules for Corporate Transparency Act

Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), which...more

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