News & Analysis as of

Comment Period FinCEN Beneficial Owner

Kelley Drye & Warren LLP

FinCEN Exempts Domestic Reporting Companies and Persons from CTA Reporting Requirements

On March 26, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an interim final rule which narrows the scope of existing beneficial ownership reporting requirements under the...more

Fenwick & West LLP

The Corporate Transparency Act: FinCEN Removes Reporting Reqs for US Companies and Persons, Sets New Deadlines for Foreign...

Fenwick & West LLP on

In a press release issued on March 21, 2025, FinCEN issued an interim final rule (IFR) revising the definition of “reporting company” to mean only those entities formed under the laws of a foreign country that have registered...more

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

Clark Hill PLC on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Montgomery McCracken

Corporate Transparency Act No Longer Applies to Entities Formed in the U.S.

Montgomery McCracken on

On March 26, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of the Treasury, published in the Federal Register an interim final rule that substantially narrows the...more

Seyfarth Shaw LLP

FinCEN Narrows Scope of Corporate Transparency Act

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On March 26, 2025, the Financial Crimes Enforcement Network’s (“FinCEN”) interim final rule (the “Interim Rule”) exempting domestic entities and U.S. persons from reporting beneficial ownership information (“BOI”) under the...more

Rivkin Radler LLP

Corporate Transparency Act Obligations for U.S. Companies Are No More

Rivkin Radler LLP on

After many years of ups and downs, legal challenges, injunctions and deadline changes, the reporting obligations under the Corporate Transparency Act (CTA) have disappeared…for most. On Friday, March 21, 2025, the Financial...more

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

McGlinchey Stafford on

Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Perkins Coie

Corporate Transparency Act: FinCEN Releases Interim Rule Limiting Application of CTA to Foreign Companies Registered to Do...

Perkins Coie on

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate...more

Bowditch & Dewey

Corporate Transparency Act – CTA for Foreign Reporting Companies Only

Bowditch & Dewey on

On Friday, March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that eliminates reporting requirements for domestic reporting companies via redefining “reporting company” to include...more

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

Ballard Spahr LLP on

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 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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

McGlinchey Stafford

FinCEN Invites Comment on Final Beneficial Ownership Information Reporting Rule

McGlinchey Stafford on

On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice inviting comment on the Beneficial Ownership Information Reporting Requirements final rule (Final BOI Reporting Rule) that was...more

Orrick, Herrington & Sutcliffe LLP

FinCEN solicits feedback on beneficial ownership reporting requirements

On January 17, the Financial Crimes Enforcement Network (FinCEN) published two notices and requests for comment in the Federal Register related to the reporting process the agency intends to use to collect beneficial...more

Ballard Spahr LLP

FinCEN Requests Comment on Proposed Beneficial Ownership Reporting Form

Ballard Spahr LLP on

Form Repeatedly Invites Response of “Unknown” As to Critical Information - The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Troutman Pepper Locke

Some Key Takeaways From the FinCEN ‎December 7, 2021 Notice of Proposed Rule Making ‎Under the ‎Corporate Transparency Act

Troutman Pepper Locke on

As a follow-up to our earlier QuickStudies ‎on the Corporate Transparency Act (“CTA”), ‎Anti-‎Money Laundering Act of 2020 ("AMLA") and art and antiquities under the AMLA, we are providing this QuickStudy to highlight a few...more

McDermott Will & Emery

FinCEN Seeks Guidance on Applying CTA Reporting Obligations to Trusts and Estates

McDermott Will & Emery on

The Corporate Transparency Act (CTA), which requires corporations, limited liability companies and other similar entities to disclose beneficial ownership information to the US Department of the Treasury’s Financial Crimes...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

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