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Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

CTA Compliance Stay Continues Despite Supreme Court Lifting Nationwide Injunction; FinCEN Recognizes Separate District Court Stay...

On January 23, 2025, the U.S. Supreme Court granted the government’s motion to lift the nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop Shop v. McHenry (formerly, Texas Top...more

Corporate Transparency Act: Entities That No Longer Exist May Need to File BOI Reports According to New FinCEN FAQs

Since January 1, 2024, when the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements became effective, a key issue has been whether companies that meet the requirements of a “reporting company” are...more

Cryptocurrency: Legal Developments and Outlook

Federal and state regulators have taken an increased interest in regulating cryptocurrencies, digital assets, and the larger blockchain ecosystem. This landscape is opaque and rapidly evolving, and many industry participants...more

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