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Senators oppose FinCEN’s Interim Final Rule on the Corporate Transparency Act

On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more

And just like that—the Corporate Transparency Act is back!

The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted. The Corporate...more

Fifth Circuit changes course—CTA preliminary injunction reinstated

On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more

FinCEN fights back after Texas Federal Court blocks the CTA

On December 3, 2024, the US District Court in the Eastern District of Texas (the Texas Federal Court) granted a nationwide preliminary injunction in favor of certain small businesses, ruling (1) the Corporate Transparency Act...more

Horizon Scanner Financial Crime - US developments - September 2024

The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources. Key developments: - US Supreme Court...more

The Corporate Transparency Act is unconstitutional - For some, and for now

On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more

Pulling back the curtain: FinCEN finalizes ultimate beneficial owner reporting rule

​​​​​​​Certain companies will soon have to give the Financial Crimes Enforcement Network (FinCEN) a look behind the corporate veil. In December 2021, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking comment on one...more

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