On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) that materially alters the Corporate Transparency Act’s (CTA) reporting requirements. Consistent with FinCEN’s March 2,...more
Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking -
On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more
As discussed last month, in early January, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction temporarily blocking enforcement of the Corporate Transparency Act (CTA) (see Smith et al....more
2/20/2025
/ Appeals ,
Beneficial Owner ,
Compliance ,
Constitutional Challenges ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
SCOTUS
Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
White Collar Crimes
On February 5, newly confirmed Attorney General Pam Bondi issued a series of guidance documents refocusing U.S. Department of Justice (DOJ) priorities for the new Administration. In addition to effectuating many of President...more
2/10/2025
/ Affirmative Action ,
Attorney General ,
Bribery ,
Cartels ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
White Collar Crimes
On February 4, President Trump’s Crypto Czar, David Sacks, held a press conference on Capitol Hill to discuss the new Administration’s plans for cryptocurrency regulation. Sacks was joined by Senate Banking Committee Chairman...more
2/6/2025
/ Bitcoin ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Trump Administration
On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more
1/27/2025
/ Appeals ,
Beneficial Owner ,
Compliance ,
Constitutional Challenges ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
SCOTUS ,
Stays
On January 21, 2025, President Trump issued an Executive Order (EO) titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” This EO raises significant new considerations for companies across the United...more
1/27/2025
/ Affirmative Action ,
Anti-Discrimination Policies ,
Civil Rights Act ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Employment Litigation ,
Employment Policies ,
Equal Employment Opportunity Commission (EEOC) ,
Executive Orders ,
Title VII ,
Trump Administration
In this episode, Wiley attorneys Vesna Harasic-Yaksic and Ira Mirsky dive into the latest developments with litigation over the Corporate Transparency Act (CTA) and potential roads ahead. They also explore its origins,...more
Just three days after reinstating the Corporate Transparency Act (CTA) reporting requirements, the U.S. Court of Appeals for the Fifth Circuit reversed course and vacated its own decision, thereby blocking all enforcement of...more
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit stayed a nationwide injunction blocking all enforcement of the Corporate Transparency Act (CTA). The Fifth Circuit’s decision effectively reinstates all...more
12/24/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On Thursday, December 5, 2024, the U.S. Department of Justice filed notice that it plans to appeal the nationwide injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop v....more
On December 3, 2024, the United States District Court for the Eastern District of Texas, in Texas Top Cop Shop v Garland et al., issued a nationwide preliminary injunction, which temporarily blocks enforcement of the...more
The Financial Crimes Enforcement Network (FinCEN) recently announced that it will provide a six-month Corporate Transparency Act (CTA) filing extension to certain reporting companies affected by one of the five hurricanes in...more
With less than three months to go until the Corporate Transparency Act’s (CTA) January 1, 2025 filing deadline, business entities formed or registered to do business in the United States before January 1, 2024 must assess (if...more
The U.S Department of Justice’s (DOJ or Department) Corporate Whistleblower Awards Pilot Program (Pilot Program) has hit the ground running, reportedly triggering more than 100 reports since it went live on August 1, 2024....more
Starting this year, certain companies are required to submit new reports related to their ownership and control that could highlight deficiencies in their small business contracting program eligibility. On September 30, 2023,...more
The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more
3/11/2024
/ Artificial Intelligence ,
CFTC ,
Compliance ,
Department of Justice (DOJ) ,
Ethics ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
To combat money laundering and other illicit activities via the use of shell companies, Congress passed the 2021 Corporate Transparency Act (CTA), which requires most U.S. businesses (and certain foreign businesses),...more
1/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
Foreign Corporations ,
Foreign Ownership ,
Limited Liability Company (LLC) ,
Reporting Requirements ,
Shell Corporations
On March 2, 2022, Attorney General Merrick B. Garland announced the launch of a new interagency task force, the KleptoCapture Task Force, focused on enforcing the recent U.S. financial sanctions and other economic...more
3/8/2022
/ Anti-Money Laundering ,
Cryptocurrency ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
FBI ,
Financial Institutions ,
FinCEN ,
IRS ,
National Security ,
NATO ,
Russia