Erin Carrigan

Morrison & Foerster LLP

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Latest Posts › Enforcement Actions

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The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

3/25/2025 / Beneficial Owner , Comment Period , Corporate Transparency Act , Enforcement Actions , Final Rules , FinCEN , Regulatory Requirements , Reporting Requirements , Trump Administration , U.S. Treasury

Treasury Department Shifts CTA to Foreign Entities

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

3/12/2025 / Beneficial Owner , Compliance , Corporate Transparency Act , Enforcement Actions , FinCEN , Foreign Entities , Regulatory Reform , Reporting Requirements , Tax Planning , U.S. Treasury

The Ping-Pong Continues – But CTA Is Still on Hold

On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more

1/28/2025 / Appeals , Beneficial Owner , Corporate Transparency Act , Enforcement Actions , FinCEN , Preliminary Injunctions , Regulatory Requirements , Reporting Requirements , SCOTUS , Stays

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