News & Analysis as of April 25, 2025

U.S. Treasury

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Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -

The Evolution of the CTA: FinCEN Removes Beneficial Ownership Reporting Requirements for US Companies and US Persons, Sets New...

McCarter & English, LLP on 3/26/2025

On March 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is issuing an interim final rule to remove the Corporate Transparency Act’s (CTA) beneficial ownership...more

Client Alert: FinCEN Narrows CTA Scope - Key Updates

Whiteford on 3/26/2025

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued an interim final rule (the “Interim Rule”) under the Corporate Transparency Act (“CTA”) whereby...more

Corporate Transparency Act – FinCEN Announces Domestic Reporting Companies Exempt From Filing

Downs Rachlin Martin PLLC on 3/25/2025

As promised, in order to reduce the burdens on placed on legitimate businesses, while still working to detect, prevent, and prosecute financial crimes, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more

CTA is No Longer Applicable to U.S. Entities and U.S. Persons; Foreign Entities Face New Rules

Cole Schotz on 3/25/2025

On Friday, March 21, 2025, FinCEN announced an interim rule that removed Beneficial Ownership (“BOI”) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act (the “CTA”). FinCEN’s new...more

FinCEN’s Weekend Present: No More CTA for U.S. Companies

Lowenstein Sandler LLP on 3/25/2025

As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more

FinCEN Beneficial Ownership Reporting No Longer Required for all U.S. Companies

Mitchell, Williams, Selig, Gates & Woodyard,... on 3/25/2025

After months of uncertainty regarding enforcement of beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA), Financial Crimes Enforcement Network (FinCEN) has issued new rules...more

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

Ropes & Gray LLP on 3/24/2025

On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Corporate Transparency Act – Reporting Obligations are Back in Effect

IR Global on 3/18/2025

The Financial Crimes’s Enforcement Network of the U.S. Treasury Department (“FinCEN”) Beneficial Ownership Information (“BOI”) reporting obligations under the Corporate Transparency Act (“CTA”) are once again back in effect....more

Corporate Transparency Act Enforcement Suspended Once Again!

Ward and Smith, P.A. on 3/14/2025

In a press release, Treasury officials confirmed they would not impose fines on U.S. citizens or domestic reporting companies, effectively pausing the reporting obligations for the time being. Under the original CTA...more

Legal Update: New Rulemaking Announced: Treasury Department Suspends Reporting, Enforcement and Fines under the Corporate...

Robinson & Cole LLP on 3/13/2025

How Did We Get Here? The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and was enacted as part of the Anti-Money Laundering Act of 2020....more

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

Bracewell LLP on 3/13/2025

If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...more

CTA Filing is Now Voluntary for US Entities and Citizens: Rule Changes Ahead

Warner Norcross + Judd on 3/12/2025

The United States Treasury Department announced on March 2, 2025, that the Beneficial Ownership Information (BOI) reporting required by the Corporate Transparency Act (CTA) is now voluntary for U.S. entities and citizens....more

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

Holland & Hart LLP on 3/12/2025

After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

Treasury Department Shifts CTA to Foreign Entities

Morrison & Foerster LLP on 3/12/2025

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

Is it Too Soon for a BOI Report Obituary?

Allen Barron, Inc. on 3/11/2025

Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....more

Corporate Transparency Act – U.S. Treasury Department Suspends Enforcement Against U.S. Citizens and Domestic Reporting Companies

Downs Rachlin Martin PLLC on 3/11/2025

The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their...more

FINCEN Filings Terminated

Lasher Holzapfel Sperry & Ebberson PLLC on 3/11/2025

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Treasury Department Will Not Enforce Corporate Transparency Act Against U.S. Businesses

Chambliss, Bahner & Stophel, P.C. on 3/10/2025

After months of uncertainty, legal challenges, and changing deadlines under the Corporate Transparency Act (CTA), the Treasury Department issued a press release on March 2, 2025, stating that it would not enforce any...more

The Treasury Department Introduces a New Twist in the CTA Saga

Kohrman Jackson & Krantz LLP on 3/10/2025

On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or...more

CTA/BOI Update - Treasury Department Announces Suspension of Enforcement for Domestic Entities

Coblentz Patch Duffy & Bass on 3/7/2025

On February 27, 2025, FinCEN announced that it would not issue fines or penalties or take any other enforcement action against any companies based on any failure to file or update beneficial ownership information (BOI)...more

U.S. Treasury Announces It Will Not Enforce the Corporate Transparency Act Against U.S. Companies and Citizens

Saul Ewing LLP on 3/7/2025

On March 1, 2025, the U.S. Department of the Treasury announced that it will not enforce the Corporate Transparency Act (CTA) against U.S. citizens or domestic reporting companies or their beneficial owners. Treasury also...more

The Corporate Transparency Act – Penalties Suspended

Tonkon Torp LLP on 3/7/2025

The Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement action for failing to file or update BOI reports by the current...more

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

Vinson & Elkins LLP on 3/7/2025

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

Navigating the Changing Landscape of Corporate Transparency Act Compliance

Allen Matkins on 3/7/2025

Both the U.S. Department of the Treasury and FinCEN, a bureau within the Treasury Department, have issued statements, which, taken together, indicate a significant reduction in the enforcement of the Corporate Transparency...more

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

Weintraub Tobin on 3/7/2025

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

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