News & Analysis as of April 26, 2025

FinCEN

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

SEC Outlines Disclosure Expectations for Offerings and Registrations of Securities in Crypto Asset Markets

Fenwick & West LLP on 4/25/2025

On April 10, 2025, the SEC’s Division of Corporation Finance (the Division) released a statement providing its views on disclosure requirements for Offerings and Registrations of Securities in the Crypto Asset Markets....more

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

Troutman Pepper Locke on 4/23/2025

As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Understanding FinCEN’s Southwest Border Geographic Targeting Order for Money Service Businesses

IR Global on 4/23/2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Southwest Border Geographic Targeting Order (GTO) aimed at Money Service Businesses (MSBs)[1]. This order is designed to enhance the monitoring and...more

Navigating New Compliance Challenges for Financial Institutions and Payment Processors: The U.S. Treasury’s Enhanced Terrorist...

Blank Rome LLP on 4/22/2025

In a significant move to combat illicit financial activities focused on cartels, the U.S. government has intensified its scrutiny of cross-border payments, particularly those linked to Mexico. This development follows the...more

SEC Staff Publishes Observations on Crypto Issuer Disclosures

Latham & Watkins LLP on 4/22/2025

On April 10, 2025, the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance (the Staff) published a Statement on Offerings and Registrations of Securities in the Crypto Asset Markets (the Statement)....more

CTA Deadline Approaching for Foreign Reporting Companies

Pillsbury Winthrop Shaw Pittman LLP on 4/21/2025

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Changes to The Corporate Transparency Act Bring Major Shift to U.S. Reporting Requirements

Tarter Krinsky & Drogin LLP on 4/21/2025

Domestic Entities No Longer Required to Disclose Beneficial Ownership Information - The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule on March 21, 2025 (effective...more

New Reporting Requirement for Certain Residential Real Estate Transfers

Harris Beach Murtha PLLC on 4/21/2025

Effective December 1, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) will implement new rules for non-financed residential real estate transfers. The purpose of the rule is to increase...more

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

King & Spalding on 4/21/2025

The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

FinCEN Interim Final Rule Signals End of Domestic Entities’ CTA Reporting Obligations

Bass, Berry & Sims PLC on 4/18/2025

After almost 18 months of uncertainty and confusion with respect to the implementation and enforcement of the Corporate Transparency Act (CTA), on Friday, March 21, the U.S. Department of Treasury’s Financial Crimes...more

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

Greenberg Glusker LLP on 4/16/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Daily Financial Regulation Update -- Tuesday, April 15, 2025

Paul Hastings LLP on 4/15/2025

April 11, 2025- The Credit Access and Inclusion Act was introduced to expand credit access for millions of Americans with limited or non-existent credit histories. April 14, 2025- Federal Reserve Board Governor...more

Cartels, China, and Fentanyl-Related Illicit Finance

DLA Piper on 4/14/2025

FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more

The (Almost) End of the Corporate Transparency Act

Snell & Wilmer on 4/14/2025

In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

FinCEN’s New Interim Final Rule on Beneficial Ownership Information Reporting

IR Global on 4/11/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced significant changes to the Beneficial Ownership Information Reporting (BOIR) requirements (Department of the Treasury, 2025). This new interim...more

Daily Financial Regulation Update -- Thursday, April 10, 2025

Paul Hastings LLP on 4/10/2025

April 9, 2025- The U.S. House Committee on Financial Services Subcommittee on Digital Assets, Financial Technology and Artificial Intelligence held a hearing entitled “American Innovation and the Future of Digital Assets...more

Next Steps for Companies that Filed CTA Reports

Mayer Brown on 4/9/2025

Millions of reporting companies breathed a sigh of relief on March 21, 2025, when the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempted all domestic entities from...more

FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the CTA

Husch Blackwell LLP on 4/9/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) removing the requirement for U.S. domestic reporting companies and U.S. persons to report Beneficial Ownership...more

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

Miller Canfield on 4/9/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting

PilieroMazza PLLC on 4/9/2025

On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership...more

FinCEN Exempts U.S. Entities from Reporting, but Uncertainty Remains

Bradley Arant Boult Cummings LLP on 4/9/2025

On March 21, 2025, the previous deadline to report Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN) under the Corporate Transparency Act (CTA), FinCEN released an interim final rule...more

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

Epstein Becker & Green on 4/9/2025

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...more

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

Patterson Belknap Webb & Tyler LLP on 4/8/2025

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

Corporate Transparency Act Update: U.S. Companies No Longer Subject to Reporting Obligations

Winstead PC on 4/8/2025

As promised, FinCEN has adopted its interim final rule and narrowed the filing requirements for Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (“CTA”). This rule exempts U.S. entities...more

New Regulatory Priorities Spring Into Focus, April 2025 - FinCEN Releases New Corporate Transparency Act Rule Exempting U.S....

Cadwalader, Wickersham & Taft LLP on 4/7/2025

On March 21st 2025, the Financial Crimes Enforcement Network (“FinCEN”) released a new interim final rule that exempts U.S. entities and U.S. beneficial owners from the reporting requirements of the Corporate Transparency Act...more

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