On February 18, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced it was providing an extension for filing beneficial ownership reports (“BOI reports”) under the Corporate Transparency Act (“CTA”) until...more
3/25/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
FinCEN ,
Foreign Entities ,
Regulatory Reform ,
Reporting Requirements ,
Trump Administration ,
U.S. Treasury
In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
3/4/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Reporting Requirements ,
U.S. Treasury
On February 17, 2025, a U.S. federal court granted the U.S. federal government’s motion to lift a nationwide injunction in place, that was preventing the enforcement by the Financial Crimes Enforcement Network (“FinCEN”) of...more
2/25/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
On January 23, 2025, the U.S. Supreme Court granted the U.S. government’s motion to stay a nationwide injunction prohibiting enforcement of the Corporate Transparency Act (“CTA”). Because a separate nationwide injunction...more
On December 3, 2024, a significant legal development occurred regarding the Corporate Transparency Act (CTA) reporting requirements. The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary...more
The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more
3/6/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
Geographic Targeting Order ,
Investment Adviser ,
National Security ,
Real Estate Transfers ,
Regulatory Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
It’s official: the Corporate Transparency Act (the “Act”) has gone into effect January 1, 2024. On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) issued its second final rule establishing the framework...more
1/2/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
FinCEN ,
New Regulations ,
Ownership Interest ,
Popular ,
Regulatory Requirements ,
Reporting Requirements
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
10/3/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
National Security ,
NPRM ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Evasion
On March 24, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial...more
4/4/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
International Tax Issues ,
New Guidance ,
Ownership Interest ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice seeking public comment on the application that will be used by individuals to obtain a unique FinCEN Identifier (a “FinCEN ID”),...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
1/11/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
British Virgin Islands ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
NPRM ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
As we previously reported, on January 1, 2021, the US enacted into federal law the Corporate Transparency Act (the “Act”), which is a new national beneficial ownership reporting regime for US companies and certain non-US...more
In a blog post early last year, we reported on the passage of the Corporate Transparency Act (“CTA”) enacted on January 1, 2021, as part of the National Defense Authorization Act for Fiscal Year 2021. As previously...more
1/20/2022
/ Beneficial Owner ,
Closely Held Businesses ,
Corporate Structures ,
Corporate Transparency Act ,
Estate Planning ,
Financial Crimes ,
FinCEN ,
Foreign Corporations ,
NDAA ,
Ownership Interest ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Trustees
On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more
4/29/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
National Security ,
NDAA ,
NPRM ,
Public Comment ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
It didn’t take very long for 2021 to bring about federal legislation that could significantly impact, or at least cause massive administrative headaches for, domestic and international private clients and their holding...more