News & Analysis as of

Beneficial Owner Corporate Transparency Act Anti-Money Laundering

Ankura

Toothless: How Proposed Changes to the Corporate Transparency Act Diminish its Efficacy

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17 Back in 2021, the U.S. Government passed the Corporate Transparency Act (CTA), which was an effort to improve upon the Bank Secrecy Act (BSA) and bolster the nation’s defenses against Money Laundering and Terrorist...more

Secretariat

Taking The Right Approach in Asset Searching and Recovery in 2025

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The tension among regulators between the push for increased transparency and the need to protect individual privacy is always apparent in asset searching exercises. This tension is a global phenomenon, central to the ongoing...more

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...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

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

Morgan Lewis

FinCEN Removes BOI Reporting Requirements for US Companies and US Persons

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The Financial Crimes Enforcement Network issued an interim final rule that removes the requirement for US companies and US persons to report beneficial ownership information to FinCEN under the Corporate Transparency Act....more

Lowenstein Sandler LLP

FinCEN’s Weekend Present: No More CTA for U.S. Companies

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As discussed in our March 4 Client Alert, following its February 27 and March 2 announcements suspending enforcement of the Corporate Transparency Act (CTA) and promising additional CTA compliance guidance, on the evening of...more

Adams & Reese

CTA Reporting No Longer Required by U.S. Domestic Companies; Foreign Companies Only, Says FinCEN

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U.S. companies can exhale. All entities created in the U.S. – including those previously known as “domestic reporting companies” and their beneficial owners – will be exempt from Corporate Transparency Act (CTA) reporting...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

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On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Ice Miller

FinCEN Issues Interim Final Rule Removing U.S. Companies and Persons from CTA Reporting Requirements

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Update: On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report Beneficial Ownership Information (BOI) under...more

Conyers

Cayman Islands: Legitimate Interest Access of Beneficial Ownership

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The Beneficial Ownership Transparency (Legitimate Interest Access) Regulations, 2024 commenced on 28 February 2025. Under these Regulations, the Cayman Islands Registrar (the “Registrar”) may provide access to the information...more

Bricker Graydon LLP

Major CTA Reporting Update: FinCEN Pauses Enforcement, Treasury Clarifies Scope

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CTA Update - On February 27th, 2025, FinCEN  put out a release stating they will not be issuing any fines or penalties or take any other enforcement actions against any companies based on a failure to file beneficial...more

Holland & Hart LLP

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

Holland & Hart LLP on

After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

Lasher Holzapfel Sperry & Ebberson PLLC

FINCEN Filings Terminated

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Ballard Spahr LLP

Treasury Announces Halt to CTA Enforcement—But Not Deadlines—for U.S. Citizens and Domestic Reporting Companies

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On March 2, 2025, the U.S. Department of Treasury announced that it will suspend enforcement of penalties and fines related to beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA) for...more

Epstein Becker & Green

CTA Enforcement Halted Again: Treasury Department Suspends CTA Requirements for Domestic Reporting Companies

In yet another update to the ongoing saga of the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN), the agency of the U.S. Department of the Treasury (“Treasury Department”) that enforces the...more

Butler Snow LLP

Treasury Department Limits Enforcement of the Corporate Transparency Act

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The Treasury Department announced on March 2nd that it does not intend to enforce any penalties or fines against either U.S. citizens or domestic reporting companies and their beneficial owners under the Corporate...more

Proskauer - Regulatory & Compliance

Ping-Pong Match Appears Over: US Companies Apparently Definitively Relieved of Compliance Obligations Under the Corporate...

The Corporate Transparency Act (the CTA) requires a range of entities, primarily smaller, unregulated companies, to file reports with FinCen, and arm of the Treasury Department, identifying the entities’ beneficial owners,...more

Greenberg Glusker LLP

Corporate Transparency Act Back in Effect: Updated BOI Compliance Deadlines - Update

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UPDATE as of 3/4/25: As of February 18, 2025, all nationwide injunctions barring the enforcement of the Corporate Transparency Act (the “CTA”) had been lifted. For approximately ten days, the CTA mandatory beneficial...more

Whiteford

Client Alert: CTA Enforcement Suspended – Key Updates on Filing Requirements

Whiteford on

On March 2, 2025, the U.S. Department of the Treasury t (“Treasury”) announced that it will not impose penalties, fines, or pursue enforcement actions against U.S. companies, citizens, or their beneficial owners for failing...more

Shipman & Goodwin LLP

Breaking News: Corporate Transparency Act - Filing Deadlines Can Be Ignored for Now and Maybe Forever for Some

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The Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) has changed the rules once again on the Corporate Transparency Act (CTA). Despite recently announcing that the new filing deadline for...more

Ballard Spahr LLP

Department of the Treasury Suspends Enforcement of the Corporate Transparency Act and Plans to Revise Rule to Limit Scope

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Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”)....more

Stoel Rives LLP

Corporate Transparency Act – Enforcement Suspended Until Further Notice

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or otherwise take any enforcement actions based on any failure to file or update...more

Pierce Atwood LLP

Out With a Bang: Treasury Restricts Corporate Transparency Act to Foreign Reporting Companies

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On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens....more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

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