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FinCEN Guts Corporate Transparency Act; Narrows Scope to Cover Only Foreign Companies and Beneficial Owners

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 Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

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

Corporate Transparency Act Reinstated; New March Deadline for BOI Reports

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

What the FCPA Criminal Enforcement Pause Means for Companies

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

AG Bondi Refocuses DOJ Priorities in New Guidance Documents

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

President Trump’s Crypto Czar Outlines Federal Government’s New Approach to Digital Assets

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

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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

Impacts of New DEI Executive Order Extend Beyond Federal Government to Private Sector

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

[Podcast] Legal Challenges to the Corporate Transparency Act: What Businesses Need to Know

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

… And Just Like That, CTA Is Halted (Yet Again)

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

Important CTA Update: CTA Filing Deadlines Immediately Reinstated with Some Extensions

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

Corporate Transparency Act Update: Government Appeals Nationwide Injunction and Announces No Liability While Injunction Remains in...

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

Federal Court Halts Enforcement of Corporate Transparency Act

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

FinCEN Extends Corporate Transparency Act Filing Deadline for Certain Companies Impacted by Recent Hurricanes

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

Last Call: The Corporate Transparency Act Filing Deadline is Looming

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

DOJ’s Corporate Whistleblower Pilot Program Hits the Ground Running: Is Your Compliance Program Ready?

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

Small Business Contractors: Beware of Corporate Transparency Act’s Potential Pitfalls

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

DOJ to Use ‘Carrots to Wield Larger Sticks’ in 2024

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

The Corporate Transparency Act’s Reporting Requirements Are Finally Here: What Do They Mean for Your Business?

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

DOJ Announces Launch of KleptoCapture Task Force in Response to Russia’s Invasion of Ukraine

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

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