News & Analysis as of

Compliance Regulatory Reform FinCEN

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on

Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

King & Spalding

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

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Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Cozen O'Connor

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...more

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Proskauer Rose LLP

New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

Proskauer Rose LLP on

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

McCarter & English, LLP

The Evolution of the CTA: FinCEN Removes Beneficial Ownership Reporting Requirements for US Companies and US Persons, Sets New...

On March 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is issuing an interim final rule to remove the Corporate Transparency Act’s (CTA) beneficial ownership...more

Cole Schotz

CTA is No Longer Applicable to U.S. Entities and U.S. Persons; Foreign Entities Face New Rules

Cole Schotz on

On Friday, March 21, 2025, FinCEN announced an interim rule that removed Beneficial Ownership (“BOI”) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act (the “CTA”). FinCEN’s new...more

Mitchell, Williams, Selig, Gates & Woodyard,...

FinCEN Beneficial Ownership Reporting No Longer Required for all U.S. Companies

After months of uncertainty regarding enforcement of beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA), Financial Crimes Enforcement Network (FinCEN) has issued new rules...more

Bracewell LLP

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

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If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...more

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

Allen Barron, Inc.

Is it Too Soon for a BOI Report Obituary?

Allen Barron, Inc. on

Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....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

ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

ArentFox Schiff on

Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

Cadwalader, Wickersham & Taft LLP

U.S. Treasury Department Suspends Enforcement of Corporate Transparency Act Against Domestic Reporting Companies and U.S....

On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more

McGlinchey Stafford

Treasury Suspends CTA BOI Reporting Penalties for U.S. Companies, Individuals

McGlinchey Stafford on

On Sunday, March 2, 2025, the U.S. Department of Treasury announced, with respect to the Corporate Transparency Act (CTA), that it will not enforce penalties or fines for beneficial ownership information (BOI) reporting...more

Vorys, Sater, Seymour and Pease LLP

Corporate Transparency Act Deadlines Extended

On February 27, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a release announcing that it intends to issue an interim final rule by March 21, 2025 that will extend the current deadlines to file or...more

Buckingham, Doolittle & Burroughs, LLC

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or other enforcement actions against companies for failing to file or update beneficial ownership...more

Warner Norcross + Judd

CTA Filing Obligations Back in Effect, but Further Developments Expected

Warner Norcross + Judd on

After weeks of legal ping-pong, the Corporate Transparency Act (CTA) reporting obligations are back in effect. On Feb. 18, 2025, the U.S. District Court for the Eastern District of Texas lifted its nationwide injunction in...more

Whiteford

Client Alert: Mandatory CTA Compliance Returns – What You Need to Know

Whiteford on

On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more

McNees Wallace & Nurick LLC

Reinstatement of the Corporate Transparency Act Reporting Obligations

Texas Federal Court Reinstates the Corporate Transparency Act The U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., has lifted the “pause” on the Corporate...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Stinson LLP

Massachusetts Adopts the Model Money Transmission Modernization Act, Joining 25 Other States

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With the passage of H.B. 4840 (the Act), the Commonwealth of Massachusetts becomes the 49th state to regulate domestic money transmission and repeals the existing money transmission law, which solely regulated foreign...more

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