The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more
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
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
On February 7, 2024Real Estate Contract FinCEN issued a Notice of Proposed Rulemaking that would require certain professionals involved in real estate closings and settlements to report information to FinCEN about...more
CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more
On September 27, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) in order to extend the deadline for reporting companies that were created or registered in 2024 to file...more
Beginning January 1, 2024, domestic entities and foreign entities registered to do business in the United States will need to comply with new information reporting requirements relating to their owners, officers, and...more
The Financial Crimes Enforcement Network (FinCEN) has proposed extending the deadline for certain companies to comply with the Corporate Transparency Act (CTA) and report their beneficial ownership information (BOI) from 30...more
The U.S. government just averted a government shutdown this past Saturday (or at least punted for another 45 days). In the last three weeks all signals from the Financial Crimes Enforcement Network (“FinCEN”) suggests the...more
The Corporate Transparency Act (CTA) will be effective on Jan. 1, 2024. For the first time, the United States now will require certain legal entities to report to the federal government identifying information about the...more
Why it matters: Information gathered and maintained by FinCEN under the CTA will be exempt from notification and record access requirements, and individuals will not be permitted to contest the contents of a report if, for...more
On January 1, 2024, the Corporate Transparency Act (the “Act” or the “CTA”) will go into effect. It is expected to impact approximately 32.6 million small and medium-sized businesses in unregulated industries in its first...more
On February 14, the Conference of State Bank Supervisors commented that FinCEN should be more explicit in its inclusion of state regulators as agencies that can request access to FinCEN’s forthcoming secure, non-public...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
FinCEN Proposes the Second Installment to the Corporate Transparency Act - On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the "Notice") in relation to the...more
On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more
Many view special purpose limited liability companies (SPE) in real estate transactions like a scrim with front lights on. The public can't see who owns the SPEs, and that causes concern. On September 29, 2022, the Department...more
In December 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting requirements of...more
FinCEN ha estado ocupada en la búsqueda de combatir la corrupción, como lo demuestra la emisión consecutiva de Avisos de Propuesta de Reglamentación (“NPRMs”). El 6/12/21, emitieron el (Proceso regulatorio para los nuevos...more
FinCEN has been busy in the quest to fight corruption as evidenced by back-to-back issuance of Notices of Proposed Rulemaking (NPRMs). On 12/6/21, they issued the (Regulatory Process for New Real Estate Sector Reporting...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The...more
On January 1, 2021, Congress enacted the National Defense Authorization Act of 2021. As part of this legislation, Congress set out new Beneficial Ownership Information Reporting Requirements (BOI Reporting Requirements) for...more
Background and Development - On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) for the Corporate Transparency Act (the “CTA”). ...more
On December 8, 2021, the U.S. Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) implementing Section 6403 of the Corporate Transparency Act (CTA), which gives the public until...more