News & Analysis as of

Beneficial Owner

Eversheds Sutherland (US) LLP

Senators oppose FinCEN’s Interim Final Rule on the Corporate Transparency Act

On May 27, 2025, Senators Sheldon Whitehouse (D-RI) and Charles E. Grassley (R-IA) submitted a comment to US Treasury Secretary Scott Bessent expressing strong opposition to the Financial Crime Enforcement Network’s Interim...more

Conyers

2025 Bermuda Insurance Bulletin

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Welcome to the latest edition of the Conyers Bermuda Insurance Bulletin. It is hard to believe that the second quarter of the year is well underway! The Bermuda (re)insurance sector has had a strong start to 2025 following a...more

Bressler, Amery & Ross, P.C.

Florida Adopts Additional Protections for Senior Investors in the 2025 Legislative Session

June is Elder Abuse Awareness Month, a time to raise awareness of the growing trend of financial exploitation, which has become one of the most prevalent forms of abuse targeting the senior population. During the 2025...more

Hogan Lovells

The EBA’s draft regulatory technical standard on customer due diligence - What should firms be worried about?

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The European Banking Authority consultation on customer due diligence under the EU’s 6th money laundering package closes on 06 June, 2025, with the EBA due to submit its findings to the European Commission’s call for evidence...more

A&O Shearman

The Register of Overseas Entities – what the real estate industry needs to know - May 2025

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Any overseas entity acquiring a Qualifying Estate must register on the Register of Overseas Entities (ROE). The ROE opened for registrations on August 1, 2022. Since September 5, 2022, an overseas entity that is not...more

Pillsbury Winthrop Shaw Pittman LLP

847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments

Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020...more

Skadden, Arps, Slate, Meagher & Flom LLP

Making Sure Newly Cautious Shareholders Get the Information They Want

Key Points - Revised guidance from the SEC regarding ownership reporting is making institutional investors circumspect about raising issues with management. - Seeking to influence a company’s executive compensation, or...more

ArentFox Schiff

Beneficial Owner Disclosure Under the New York LLC Transparency Act

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After a rollercoaster of activity related to the federal Corporate Transparency Act (CTA), the US Treasury Department (Treasury) announced on March 2 that it will not enforce any penalties or fines associated with beneficial...more

K&L Gates LLP

FinCEN's New Reporting Requirements for Nonfinanced Residential Real Estate Transactions

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Effective 1 December 2025, the Financial Crimes Enforcement Network (FinCEN) will implement comprehensive nationwide regulations aimed at increasing transparency and combating money laundering in the United States residential...more

Fenwick & West LLP

Texas Legislature Approves Significant Changes to Its Corporate Law, Incentivizing Relocation to Texas and Listing on Texas-based...

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Delaware has long been the jurisdiction of choice for corporations, but certain recent controversial judicial decisions have resulted in a number of high-profile companies reincorporating (or considering reincorporation) into...more

Pillsbury Winthrop Shaw Pittman LLP

The Ironic Impact of FinCEN’s New CTA Regulations on New York’s LLC Transparency Act

The NYS LLC Transparency Act (the “New York Act”) became law in January 2024 and takes effect on January 1, 2026. When in effect, it would require limited liability companies formed or qualified to do business in New York to...more

McDermott Will & Emery

Economic Ownership of Shares Transferred as Collateral

Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

WilmerHale

The New German Government’s Agenda on Compliance

WilmerHale on

On May 5, 2025, the Christian Democratic Union of Germany (CDU) and the Christian Social Union (CSU) entered into a coalition agreement (Coalition Agreement) with the Social Democratic Party of Germany (SPD) (together with...more

Carey Olsen

British Virgin Islands investment funds - Spring 2025 update

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Our investment funds team outline the latest developments within the investment funds market in the British Virgin Islands ("BVI"), including the funds statistics from the British Virgin Islands Financial Services Commission...more

Walkers

Channel Islands Regulatory Update: April 2025

Walkers on

This update provides an overview of the recent key publications, findings and reports issued during the last quarter....more

Carey Olsen

Doing business in the Cayman Islands guide (Legal 500)

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The Cayman Islands is a common law jurisdiction, which is based on the English model. It comprises statute law and binding case precedents. English and British Commonwealth case authorities are generally persuasive, but not...more

Cadwalader, Wickersham & Taft LLP

Asset Disposals in the "Real World"

The recent case of A Sajedi and others v HMRC [2025] UKFTT 297 (TC) in the UK First-tier Tribunal (“FTT”) is an interesting example of a UK taxation tribunal intervening to decide a litigated matter on grounds that neither...more

K&L Gates LLP

The Latest OFSI Property and Related Services Threat Assessment

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The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more

Holland & Knight LLP

DOD Proposed Rule Will Expand FOCI Requirements to Non-Classified Defense Contracts

Holland & Knight LLP on

U.S. Department of Defense (DOD) contractors with foreign ownership, control, or influence (FOCI) soon will face new requirements. Though cleared DOD contractors have long been bound by FOCI obligations, the new rule will...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

K&L Gates LLP

What Legal Services Providers Need to Learn From OFSI's Legal Services Threat Assessment

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In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Tarter Krinsky & Drogin LLP

Changes to The Corporate Transparency Act Bring Major Shift to U.S. Reporting Requirements

Domestic Entities No Longer Required to Disclose Beneficial Ownership Information - The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule on March 21, 2025 (effective...more

Harris Beach Murtha PLLC

New Reporting Requirement for Certain Residential Real Estate Transfers

Effective December 1, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) will implement new rules for non-financed residential real estate transfers. The purpose of the rule is to increase...more

Bass, Berry & Sims PLC

FinCEN Interim Final Rule Signals End of Domestic Entities’ CTA Reporting Obligations

Bass, Berry & Sims PLC on

After almost 18 months of uncertainty and confusion with respect to the implementation and enforcement of the Corporate Transparency Act (CTA), on Friday, March 21, the U.S. Department of Treasury’s Financial Crimes...more

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