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FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

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

FinCEN Announces No Penalties for BOI Reporting Failures

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

Corporate Transparency Act Burden Highlighted by Certain Holding Company Structures

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

And Now We Wait – DOJ Appeals to Fifth Circuit and FinCEN Makes a Statement on CTA Preliminary Injunction

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

Now What? – Texas Court Nationally Enjoins Corporate Transparency Act as “Likely Unconstitutional”

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

FinCEN Update to Beneficial Ownership FAQs and Paycheck Protection Program FAQs

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

FinCEN and OFAC Issue First Joint Action in Cryptocurrency Market

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

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