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Corporate Transparency Act Bank Secrecy Act

Perkins Coie

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

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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

Moore & Van Allen PLLC

CTA Reporting Relief: FinCEN Interim Rule Exempts US Companies from Reporting Beneficial Ownership & Foreign Companies from...

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The Financial Crimes and Enforcement Network of the U.S. Treasury Department (FinCEN) on March 21, 2025 announced an interim final rule (the “Interim Rule”) which, if finalized in its current form, exempts all domestic...more

Eversheds Sutherland (US) LLP

Dual Registrant Regulatory Roundup - January 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

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Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Foodman CPAs & Advisors

Beneficial Ownership Information Access

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On 11/15/24, FinCEN updated two Beneficial Ownership Information Access FAQs. The theme of the 11/15/24 update is Beneficial Ownership Access in accordance with the Corporate Transparency Act. FinCEN had previously update...more

Ballard Spahr LLP

Corporate Transparency Act Litigation Update:  Eleventh Circuit Hears Argument, and District of Oregon Rejects Preliminary...

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Various industry groups have filed lawsuits in multiple federal districts challenging the constitutionality of the Corporate Transparency Act (“CTA”). The first such suit, filed in the Northern District of Alabama, resulted...more

Troutman Pepper Locke

Treasury Department Releases Semiannual Regulatory Agenda

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On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more

BCLP

Synapse Failure Spurs FDIC To Specify Record Keeping for Bank Sponsored Fintechs

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The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more

Troutman Pepper Locke

FINCEN Adopts New Rule on Cash Sales ‎of Residential Real Estate

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On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”) requiring reports by “reporting persons” concerning real estate transfers to a legal entity or trust of certain...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

Buchalter

Corporate Transparency Act Found Unconstitutional for Certain Businesses

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In March 2024, the Northern District of Alabama held that Congress exceeded its Constitutional authority by enacting the Corporate Transparency Act (“CTA”). The CTA requires variety corporate entities—everything from LLCs to...more

Moritt Hock & Hamroff LLP

MHH Condo/Co-op Digest, Vol. V - March 2024

This newsletter explores the emerging legal topics and issues affecting the condominium and cooperative services industry. Thought-leading attorneys from Moritt Hock & Hamroff’s Condominium and Cooperative Services Practice...more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

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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

Ballard Spahr LLP

Federal District Court Ruling: The CTA is Unconstitutional

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On March 1, Judge Liles C. Burke of the Northern District of Alabama issued a Memorandum Opinion (“Opinion”) and Final Judgment, finding that the Corporate Transparency Act (“CTA”) is unconstitutional....more

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more

McGlinchey Stafford

FinCEN Issues Access Rule, Small Entity Compliance Guide for Beneficial Ownership Information

McGlinchey Stafford on

The Corporate Transparency Act (CTA) requires certain businesses to provide beneficial ownership information (BOI) to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). BOI received by FinCEN...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Amundsen Davis LLC

Enhancing Transparency in Real Estate: FinCEN's New Reporting Requirements for Non-Financed Transfers

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On February 7, 2024Real Estate Contract FinCEN issued a Notice of Proposed Rulemaking that would require certain professionals involved in real estate closings and settlements to report information to FinCEN about...more

Foodman CPAs & Advisors

BOI Destinatarios Autorizados

El 12/21/23, FinCEN emitió una regla final que implementa las disposiciones de acceso y salvaguardia de la Ley de Transparencia Corporativa (CTA) (la “Regla de Acceso”). La Regla de Acceso tiene como objetivo garantizar que:...more

Foodman CPAs & Advisors

BOI Authorized Recipients

On 12/21/23, FinCEN issued a final rule implementing the access and safeguard provisions of the Corporate Transparency Act (CTA) (the “Access Rule”). The Access Rule aims to ensure that: (1) only BOI authorized recipients...more

Troutman Pepper Locke

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

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On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

Husch Blackwell LLP

Corporate Transparency Act Guide

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On January 1, 2024, the Corporate Transparency Act (CTA) will go into effect, and if your business is deemed to be a Reporting Company under the CTA, the clock will begin ticking on new federal reporting obligations....more

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