News & Analysis as of

Enforcement Actions Financial Crimes Beneficial Owner

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

The Volkov Law Group

Episode 377 -- Refocusing Due Diligence on Cartels and TCOs

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Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...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

Kohrman Jackson & Krantz LLP

The Treasury Department Introduces a New Twist in the CTA Saga

On March 2, 2025, the U.S. Department of Treasury threw a new twist into the ongoing Corporate Transparency Act (CTA) enforcement saga by announcing that it will not enforce any fines or penalties against any U.S. citizens or...more

Proskauer - Regulatory & Compliance

Ping-Pong Match Appears Over: US Companies Apparently Definitively Relieved of Compliance Obligations Under the Corporate...

The Corporate Transparency Act (the CTA) requires a range of entities, primarily smaller, unregulated companies, to file reports with FinCen, and arm of the Treasury Department, identifying the entities’ beneficial owners,...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

Shumaker, Loop & Kendrick, LLP

Client Alert: The Treasury Department Announces It Will Not Issue Fines or Penalties in Connection with Beneficial Ownership...

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced it will “…not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update...more

Pierce Atwood LLP

Corporate Transparency Act Returns: New Deadline March 21, 2025

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Newly Formed Entities Have 30 Days to File - On February 17, 2025, the Eastern District of Texas in Smith v. United States Department of the Treasury lifted the last remaining nationwide preliminary injunction on...more

UB Greensfelder LLP

What the Latest Reinstatement of the Corporate Transparency Act Means

UB Greensfelder LLP on

Filing requirements under the Corporate Transparency Act (CTA) have been reinstated. Per FinCEN’s (Financial Crimes Enforcement Network’s) most recent Alert released on February 18, 2025, the new deadline for filing...more

Cozen O'Connor

Latest CTA Injunction Stayed

Cozen O'Connor on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more

McDermott Will & Schulte

Corporate Transparency Act Update: Reporting Obligations Reinstated

On February 18, 2025, the US District Court for the Eastern District of Texas in Smith v. US Department of the Treasury, No. 6:24-cv-336-JDK, entered an order staying (pausing) the nationwide preliminary injunction against...more

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

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On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

DLA Piper

CTA Update: Supreme Court Grants Stay of Preliminary Injunction on Corporate Transparency Act

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On January 23, 2025, the Supreme Court of the United States granted the federal government a stay of the preliminary injunction foreclosing enforcement of the Corporate Transparency Act (CTA) in McHenry v. Texas Top Cop Shop,...more

McDermott Will & Schulte

Corporate Transparency Act Update: Nationwide Injunction Continues

On January 23, 2025, the Supreme Court of the United States issued a stay of the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) and the Beneficial Ownership...more

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

DLA Piper on

Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Kohrman Jackson & Krantz LLP

CTA Reporting Remains Voluntary Despite Recent Supreme Court Decision

On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction issued in Texas Top Cop Shop, Inc. et al. v. Garland et al., creating further legal uncertainty surrounding the Corporate Transparency Act...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Fifth Circuit Issues an Expedited Appeal of CTA Nationwide Injunction

December was an eventful month for the Corporate Transparency Act (CTA). The latest court ruling in the CTA conflict occurred on December 26, 2024, in Texas Top Cop Shop, Inc., et al. v. Garland, et al., when the Fifth...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

Bass, Berry & Sims PLC

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

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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

Orrick, Herrington & Sutcliffe LLP

Record Anti-Money Laundering Fine Imposed on Swedbank

I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

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The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

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