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The FTC's Proposed Rule to Fight Impersonation Scams
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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more
To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more
2023 was a pivotal year for the emerging companies, creating new categories of winners and losers across the board. Emerging companies incorporating artificial intelligence or that have clear line of sight to positive cash...more
When the Corporate Transparency Act (CTA) goes into effect in January 2024, millions of companies will face new beneficial ownership reporting obligations. The Financial Crimes Enforcement Network has proposed allowing...more
On September 27, 2023, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) to extend the deadline — from 30 days to 90 days — for domestic and foreign...more
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
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act)...more
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more
The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...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 This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
On December 8, 2021, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register its first installment of widely anticipated Proposed Rules regarding the Corporate Transparency Act of 2019 (CTA). The...more
Starting this year (2022), most private, domestic U.S. entities formed from and after January 1, 2021 will be required to self-report to the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) certain basic...more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more
WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more
On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated proposed rule that would implement key provisions of the Corporate Transparency Act (CTA), a...more
The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week a Notice of Proposed Rulemaking (NPRM) to implement the beneficial ownership reporting requirements set forth in the Corporate...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published an Advance Notice of Proposed Rulemaking (the Proposed Rule) seeking input from the public on the implementation of a reporting...more