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Beneficial Owner Proposed Rules Anti-Money Laundering

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

Butler Snow LLP on

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

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

Walkers

Channel Islands Regulatory Update - January 2025

Walkers on

On 5 December 2024 the UK's Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 came into force. The UK Regulations are made under the UK Sanctions and Anti-Money Laundering Act 2018 ("SAMLA") and make...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

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As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

BCLP on

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

King & Spalding

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

King & Spalding on

On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Ballard Spahr LLP

FATF Re-Rates United States as “Largely Compliant” with Beneficial Ownership Recommendation

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The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Proposes New Rule to Deter Money Laundering in the Residential Real Estate Sector

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “Proposed Rule”) designed to combat and deter money laundering in the U.S....more

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

Dorsey & Whitney LLP on

Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Ballard Spahr LLP on

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

Cadwalader, Wickersham & Taft LLP

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Troutman Pepper Locke

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper Locke on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Ballard Spahr LLP

FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

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The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more

Morgan Lewis

FinCEN Proposes New Rule on Beneficial Ownership Information Access and Safeguards for Corporate Transparency Act

Morgan Lewis on

The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more

Perkins Coie

FinCEN Issues Proposed Rule for Accessing Ownership Information Under the Corporate Transparency Act

Perkins Coie on

The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more

Neal, Gerber & Eisenberg LLP

The Corporate Transparency Act of 2019: A New Era of Beneficial Ownership Disclosure and Entity Formation

On December 8, 2021, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register its first installment of widely anticipated Proposed Rules regarding the Corporate Transparency Act of 2019 (CTA). The...more

Harris Beach Murtha PLLC

U.S. Treasury Targets Money Laundering, Terrorism And Tax Fraud With Proposed Beneficial Ownership Rules

The Corporate Transparency Act of 2020 (the “CTA”) was enacted in January 2021 as part of the Anti-Money Laundering Act of 2020 to prevent the use of shell companies to evade anti-money laundering and economic sanctions...more

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