News & Analysis as of

Disclosure Requirements Financial Crimes Corporate Transparency Act

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

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

Greenberg Glusker LLP on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...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

Vicente LLP

Corporate Transparency Act, We Hardly Knew Ye: What the Interim Final Rule Means for U.S. Businesses

Vicente LLP on

The Corporate Transparency Act (CTA) has undergone a significant shift. The FinCEN recently issued a new Interim Final Rule (IFR), dramatically narrowing the law's reach. As a result, most U.S. companies no longer have...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

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Charles E. Rounds, Jr. - Suffolk University...

The federal Corporate Transparency Act (CTA), whose constitutionality is currently being tested in the courts, creates another...

The federal Corporate Transparency Act (CTA), effective January 1, 2024, whose constitutionality is currently being tested in the courts, follows in the footsteps of the IRC in that it creates a limited statutory exception...more

Buchalter

Corporate Transparency Act Found Unconstitutional for Certain Businesses

Buchalter on

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

Falcon Rappaport & Berkman LLP

Constitutional Clash: U.S. District Court Landmark Decision Declares the Corporate Transparency Act Unconstitutional

In 2021, Congress passed the Corporate Transparency Act (CTA), which will be administered and enforced by the Financial Crimes Enforcement Network (“FinCEN”) of the United States Treasury Department, in an effort to implement...more

Willcox & Savage

Federal District Court Rules Corporate Transparency Act Unconstitutional

Willcox & Savage on

On March, 1, 2024, the U.S. District Court for the Northern District of Alabama held that the federal Corporate Transparency Act (CTA) is unconstitutional. The plaintiffs in the case are the National Small Business...more

Ballard Spahr LLP

The CTA at Two Months: Key Updates and Action Items

Ballard Spahr LLP on

After years of anticipation, the Corporate Transparency Act (the CTA) officially went into effect on January 1, 2024. Now that we are two months into the CTA era, below are a few updates and recommended action items based on...more

Venable LLP

Looming CTA Disclosure Requirements and Healthcare Providers

Venable LLP on

The Federal Corporate Transparency Act (the CTA), 31 U.S.C. §5336, will soon require certain entities to disclose to the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) certain pieces of identifying information...more

Ankura

Economic Crime and Corporate Transparency Act 2023: Key Considerations for Addressing Failure to Prevent Fraud

Ankura on

The Economic Crime Bill received Royal Assent on 26 October 2023. Included in the Act is the failure to prevent fraud offence, under which large companies will be liable when a specified fraud offence is committed by an...more

Polsinelli

What the Health Care Industry Needs to Know About the Corporate Transparency Act

Polsinelli on

A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more

Bass, Berry & Sims PLC

The Corporate Transparency Act: A Primer for “Small” Businesses

Bass, Berry & Sims PLC on

The Corporate Transparency Act (CTA), which aims to curb illicit financial activities like money laundering and other fraudulent activities, will go into effect on January 1, 2024. Consequentially, many types of businesses,...more

Cranfill Sumner LLP

Navigating Transparency: Countdown to Compliance with the Corporate Transparency Act in North Carolina

Cranfill Sumner LLP on

In recent years, governments across the United States have taken steps to enhance corporate transparency. The Corporate Transparency Act (CTA), enacted in 2020 as part of the National Defense Authorization Act for Fiscal Year...more

Lowenstein Sandler LLP

Bipartisan Bill Seeks to Delay FinCEN’s Beneficial Ownership Reporting Requirements

Lowenstein Sandler LLP on

On August 1, a bipartisan bill was introduced to modify the Corporate Transparency Act (CTA). The Protect Small Businesses and Prevent Illicit Financial Activity Act (H.R. 5119) was introduced in the U.S. House of...more

Benesch

Corporate Transparency Act Imposes New Federal Reporting Requirements on Small Businesses

Benesch on

With its effective date on the horizon, many businesses will now need to file reports with the U.S. Dept of Treasury FinCEN division under the new Corporate Transparency Act. This Act, which is part of Congress’ Anti-Money...more

Venable LLP

Navigating the Corporate Transparency Act

Venable LLP on

Federal law will soon require for the first time that certain companies disclose personally identifiable information about themselves and their beneficial owners and company applicants to U.S. Treasury’s Financial Crimes...more

Fox Rothschild LLP

Law Firms Guiding Compliance With Corporate Transparency Act as FinCEN Sets Deadlines

Fox Rothschild LLP on

The Corporate Transparency Act is now poised to take effect on January 1, 2024 (the “Effective Date”), and will immediately impose sweeping new disclosure duties when new entities are formed. During 2024, the other CTA shoe...more

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