News & Analysis as of

Reporting Requirements Enforcement

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...more

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

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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

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Seward & Kissel LLP

Update: U.S. Companies and U.S. Persons No Longer Required to Provide Beneficial Ownership Information under the Corporate...

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Following the Treasury Department’s announcement regarding the removal of fines and penalties under the Corporate Transparency Act (“CTA”), the Financial Crimes Enforcement Network (“FinCEN”) has now advised that U.S....more

Morgan Lewis

EU Pay Transparency Directive: The Current Status and How To Prepare

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EU member states have until 7 June 2026 to implement the EU Pay Transparency Directive (the Directive) into their domestic law. This LawFlash summarises the Directive’s key requirements, considers the current implementation...more

Chambliss, Bahner & Stophel, P.C.

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

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

Morgan Lewis

CFTC Enforcement Replaces Previous Cooperation Guidance With New Mitigation Credit Matrix

Morgan Lewis on

The Division of Enforcement of the US Commodity Futures Trading Commission (CFTC or Commission) recently issued an advisory revoking prior guidance for its staff in recommending enforcement resolutions (the Advisory) and...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Announces Changes to the BOI Reporting Requirements Under the Corporate Transparency Act

On March 2, 2025, the Department of Treasury confirmed in a press release that it will not enforce any penalties or fines associated with the BOI reporting requirements under the existing regulatory deadlines...more

Morris, Manning & Martin, LLP

FinCEN Announces Deadline Extension and Enforcement Pause

The ongoing saga of the Corporate Transparency Act (CTA) continues! On the evening of February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced three key developments. What Does This Mean for Your...more

Akin Gump Strauss Hauer & Feld LLP

Making America Healthy Again By Empowering Patients With Clear, Accurate, and Actionable Healthcare Pricing Information (Trump EO...

The EO announces a policy of the United States to put patients first and ensure they have the necessary information to make well-informed healthcare decisions. The order builds upon Executive Order 13877 (Improving Price and...more

Coblentz Patch Duffy & Bass

UPDATE – Mandatory BOI Reporting Requirements Reinstated; March 21, 2025 Due Date

In our last client alert about the Corporate Transparency Act (CTA), an injunction against enforcement of the CTA remained in effect. On February 17, 2025, the injunction was stayed, and there are currently no impediments to...more

Kohrman Jackson & Krantz LLP

The Corporate Transparency Act Returns: What You Need to Know

Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. In the latest in a line of dizzying decisions surrounding the CTA, in Smith v. U.S....more

Dickinson Wright

Texas Court Recognizes Supreme Court Ruling, Reinstates BOI Filing Requirement

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The Corporate Transparency Act (CTA or the Act) is back in play. In an Order released on Feb. 17, 2025, a federal district court in the Eastern District of Texas stayed its Order from Jan. 7, 2025, which had enjoined...more

Sheppard Mullin Richter & Hampton LLP

The Return of the CTA: FinCEN Confirms that Beneficial Ownership Information Reporting Requirements are Back in Effect with a New...

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that beneficial ownership information reporting requirements under the Corporate Transparency Act (“CTA”) are back in effect with a new...more

Perkins Coie

Corporate Transparency Act: FinCEN Reinstates Reporting Requirements with March 21 Deadline

Perkins Coie on

Earlier this week, the Financial Crimes Enforcement Network (FinCEN) issued a new notice confirming that the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements are back in effect....more

Whiteford

Client Alert: Mandatory CTA Compliance Returns – What You Need to Know

Whiteford on

On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more

Baker Botts L.L.P.

Corporate Transparency Act Reporting Obligations Back In Effect With Extension

Baker Botts L.L.P. on

Reporting obligations related to the Corporate Transparency Act (“the CTA”) are set to return. As we previously reported, on December 3, 2024, a federal judge in Texas (Texas Top Cop Shop, Inc. v. Bessent) issued a...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect: March 21 Is the New Deadline to File Beneficial Ownership Reports

Fox Rothschild LLP on

The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Adams & Reese

FinCEN Gets Green Light from Texas Court to Enforce the Corporate Transparency Act

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The courts have spoken, and the last nationwide injunction has fallen. FinCEN has a green light to enforce the Corporate Transparency Act, and the federal agency has set a new deadline in March for companies to report....more

Clark Hill PLC

CTA Back in Effect – Reports Now Due March 21

Clark Hill PLC on

On Feb. 18, the U.S. District Court in Smith, et al v. U.S. Dept. of Treasury stayed the last remaining nationwide injunction on enforcement of the Corporate Transparency Act. After this court action, FinCEN announced that...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Governor Hochul Signs Amendment Extending Key Effective Date for the New York Retail Worker Safety Act

In what might have been a Valentine’s Day gift for retail employers across New York, on February 14, 2025, Governor Kathy Hochul signed into law an amendment to the New York Retail Worker Safety Act (S8358B/A8947C, Chapter...more

Morrison & Foerster LLP

CPSC’s 2024 Year in Review

In recent years, the Consumer Product Safety Commission (CPSC) has increased pressure on consumer product companies through various enforcement mechanisms. The increase in the frequency and amount of civil penalties sought by...more

Paul Hastings LLP

New York State Bill Seeks to Impose Greenhouse Gas Emissions Disclosure Requirements

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On January 27, 2025, N.Y Sen. Brad Hoylman-Sigal (D), introduced Senate Bill 3456 (“SB 3456”) calling for the adoption of the Climate Corporate Data Accountability Act (“CCDAA”). The bill is substantively identical to...more

Morrison & Foerster LLP - Class Dismissed

EPA’s PFAS Enforcement Plan Advances As Two PFAS Reporting Requirements Set To Go Into Effect

EPA Adds Nine New PFAS to List of Chemicals Subject to Toxic Chemical Release Reporting Under the Emergency Planning and Community Right-to-Know Act and The Pollution Prevention Act On January 6, 2025, the EPA published a...more

Mayer Brown Free Writings + Perspectives

SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance

On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more

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