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FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to (1) postpone until January 1, 2028, the effective date of the final anti-money laundering rule...more

Corporate Transparency Act Reporting Requirements Halted Again – For Now

On December 26, 2024, the US Court of Appeals for the Fifth Circuit issued an order in Texas Top Cop Shop, Inc. et al. v. Garland et al., that effectively pauses beneficial ownership information (BOI) reporting requirements...more

US Corporate Transparency Act Reporting Requirements Back in Effect, With Deadline Extensions

In an order dated December 23, 2024, in the case Texas Top Cop Shop, Inc. et al. v. Garland et al., the US Court of Appeals for the Fifth Circuit issued a stay pending appeal of a preliminary injunction issued by a lower...more

Federal District Court Enjoins Enforcement of Corporate Transparency Act Beneficial Ownership Information Reporting Requirements...

On Tuesday, December 3, 2024, the US District Court for the Eastern District of Texas issued an order in favor of the plaintiffs in Texas Cop Shop, Inc. et al. v. Garland et al., granting the plaintiffs’ motion for...more

FinCEN Issues Final Rule Requiring Investment Advisers to Establish Anti-Money Laundering Programs

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that expressly includes certain investment advisers in the definition of a “financial institution”...more

US Corporate Transparency Act Reporting Deadline Approaching – What You Need to Know

Millions of existing companies formed or registered in the US on or before December 31, 2023, are required to file beneficial ownership information (BOI) reports on or before January 1, 2025, pursuant to the requirements of...more

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

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