In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more
7/10/2025
/ Banks ,
Customer Identification Program (CIP) ,
Data Collection ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Patriot Act ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Taxpayer Identification Number ,
Third-Party ,
U.S. Treasury
Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more
On Sunday, March 2, 2025, the U.S. Department of Treasury announced, with respect to the Corporate Transparency Act (CTA), that it will not enforce penalties or fines for beneficial ownership information (BOI) reporting...more
On February 27, 2025, FinCEN announced “it will not issue any fines or penalties or take any other enforcement actions against companies based on any failure to file or update beneficial ownership information (BOI) reports...more
2/28/2025
/ Beneficial Owner ,
Compliance ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement Actions ,
Final Rules ,
FinCEN ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more
2/20/2025
/ Beneficial Owner ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
National Security ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business ,
U.S. Treasury
On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more
2/7/2025
/ Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Enforcement Actions ,
Final Rules ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more
1/27/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
SCOTUS ,
Stays
In a rollercoaster of a ride, the merits panel of the U.S. Court of Appeals for the Fifth Circuit, on December 26, 2024, vacated the prior order of the Fifth Circuit’s motions panel staying the preliminary injunction...more
The United States Court of Appeals for the Fifth Circuit on December 23, 2024, issued an order lifting a prior order issued by a federal district court in the Eastern District of Texas granting a nationwide preliminary...more
12/30/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
Much has been written about the filing requirements under the Corporate Transparency Act (CTA) in the last year. Currently, enforcement of the CTA has been placed on hold. On December 3, 2024, a federal district court in the...more
On December 5, 2024, the Department of Justice (DOJ), on behalf of the Department of the Treasury, filed a Notice of Appeal to the Fifth Circuit challenging the nationwide preliminary injunctive relief from compliance with...more
On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered into a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) and compliance with the...more
On March 29, 2024, the Financial Crimes and Enforcement Network (FinCEN) in collaboration with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union...more
The Corporate Transparency Act (CTA) is unconstitutional, according to a March 1, 2024, ruling by Judge Liles Burke of the U.S. District Court for the Northern District of Alabama. The National Small Business Association...more
The Corporate Transparency Act (CTA) requires certain businesses to provide beneficial ownership information (BOI) to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). BOI received by FinCEN...more
In January 2024, the Financial Crimes Enforcement Network (FinCEN) updated and added to its Frequently Asked Questions (FAQs) on the Beneficial Ownership Information Report (BOI) website. Additionally, on January 12, 2024,...more
On November 16, 2023, the United States Department of the Treasury Financial Crimes Enforcement Network (FinCEN) updated the Beneficial Ownership Information (BOI) FAQs in response to inquiries received relating to the BOI...more
On September 27, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) in order to extend the deadline for reporting companies that were created or registered in 2024 to file...more
On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice inviting comment on the Beneficial Ownership Information Reporting Requirements final rule (Final BOI Reporting Rule) that was...more
On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that establishes a beneficial ownership information (BOI) reporting requirement that will require reporting...more
On October 11, 2022, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) acted in parallel to issue the first joint action in the cryptocurrency market against Bittrex. Bittrex...more
The market for digital assets has exploded in recent years. Digital and virtual currency activities provide great opportunities financially and technologically. However, such currencies can be utilized for illicit activity...more