The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took a historic step in combating the fentanyl crisis on June 25, 2025, by exercising, for the first time, the expansive authorities granted...more
On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more
Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more
3/3/2025
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
FinCEN ,
New Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Temporary Hold
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
As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the Corporate Transparency Act (CTA)...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays
June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more
8/5/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Penalties ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The CTA and Legal Challenges -
The CTA is a sweeping new anti-money-laundering law that, as of January 1, 2024, requires most entities formed or registered to do business in the United States to disclose detailed...more
As discussed in our prior Update on the Corporate Transparency Act (CTA), anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial...more
The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more
Key portions of the Corporate Transparency Act (CTA) will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the...more
12/11/2023
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more
12/5/2023
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Business Ownership ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Exemptions ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Reporting Requirements
The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more
Regulated gaming is booming in the United States. This is particularly true of newer forms of gambling, such as skill games, fantasy sports, and social casino games played on the internet and mobile applications. In fact,...more
7/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Emerging Technology Companies ,
Enforcement ,
Fantasy Sports ,
Financial Institutions ,
FinCEN ,
Gambling ,
Gambling Acts ,
Gaming ,
Investigations ,
Online Gaming ,
Regulatory Requirements ,
Sports Gambling ,
State and Local Government ,
UK ,
Venture Capital ,
Video Games ,
White Collar Crimes
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
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more
10/4/2022
/ AML/CFT ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Jurisdiction ,
Limited Liability Company (LLC) ,
Penalties ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
3/22/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Russia ,
SDN List ,
SWIFT ,
U.S. Treasury ,
UK ,
Ukraine
The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) on December 6, 2021, soliciting comments on the potential extension of the Bank Secrecy Act (BSA), and the attendant...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
On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more
As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more
7/15/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Disclosure Requirements ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
New Rules ,
Reporting Requirements ,
Terrorist Financing Regulations ,
U.S. Treasury
On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more
4/13/2021
/ Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Criminal Penalties ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Senior Foreign Political Figures (SFPFs) ,
Subpoenas ,
Virtual Currency ,
Whistleblower Awards