News & Analysis as of

Filing Requirements Regulatory Requirements Anti-Money Laundering

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

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On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Bradley Arant Boult Cummings LLP

Will There Be Light? FinCEN’s New Reporting Rule Faces Legal Challenge

The U.S. real estate market has long been a cornerstone of the American dream—a path to stability, investment, and generational wealth. But at the margins, that same market has also provided an opportunity for illicit actors...more

Procopio, Cory, Hargreaves & Savitch LLP

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

Harris Beach Murtha PLLC

New Reporting Requirement for Certain Residential Real Estate Transfers

Effective December 1, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) will implement new rules for non-financed residential real estate transfers. The purpose of the rule is to increase...more

IR Global

FinCEN’s New Interim Final Rule on Beneficial Ownership Information Reporting

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced significant changes to the Beneficial Ownership Information Reporting (BOIR) requirements (Department of the Treasury, 2025). This new interim...more

Morrison & Foerster LLP

Off Again, On Again: The CTA Revived

Key Takeaway: Following a court decision on February 18, 2025, the Corporate Transparency Act’s (CTA) beneficial ownership reporting requirements are once again in effect. Most companies will have until Friday, March 21,...more

Flaster Greenberg PC

Corporate Transparency Act Updates

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(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...more

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

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After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

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FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more

McGlinchey Stafford

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

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The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more

Carey Olsen

Amendments to the BVI Business Companies Act

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On 2 January 2025, the BVI Business Companies (Amendment) Act, 2024 and the BVI Business Companies and Limited Partnership (Beneficial Ownership) Regulations, 2024 (the “Amendments”) came into effect. The Amendments impact...more

McGlinchey Stafford

Game On: Preliminary Injunction on Corporate Transparency Act Lifted; Filing Deadlines Extended

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The United States Court of Appeals for the Fifth Circuit on December 23, 2024, issued an order lifting a prior order issued by a federal district court in the Eastern District of Texas granting a nationwide preliminary...more

Kerr Russell

CTA Reporting Requirements Resume: FinCEN Announces Extended Filing Deadlines

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On December 23, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit issued an order in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al. staying the nationwide preliminary injunction...more

Procopio, Cory, Hargreaves & Savitch LLP

Corporate Transparency Act Compliance Mandate Reinstated and Filing Deadline Extended

Reporting companies are once again required to comply with the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements, although the deadline has been shifted slightly to allow those...more

Rivkin Radler LLP

Corporate Transparency Act Injunction Lifted, Deadline to File Extended

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On Monday, December 23, 2024, the U.S. Fifth Circuit Court of Appeals (the “Fifth Circuit”) lifted a Texas district court’s order enjoining the Financial Crimes Enforcement Network’s (“FinCEN’s) enforcement of the Corporate...more

Roetzel & Andress

Fifth Circuit Lifts Injunction on Corporate Transparency Act: New Reporting Deadlines Announced

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On December 23, 2024, the United States Court of Appeals for the Fifth Circuit issued an order granting the Department of Justice’s emergency motion for a stay pending appeal, lifting the nationwide injunction blocking the...more

Rivkin Radler LLP

Fifth Circuit Resurrects Corporate Transparency Act; New Filing Deadline 1/13/25

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On December 23, the Fifth Circuit Court of Appeals lifted the stay on the Corporate Transparency Act (CTA), reinstating its enforcement nationwide. The CTA requires certain non-exempt entities to report the identities of...more

Allen Matkins

Updates to the Corporate Transparency Act's Beneficial Ownership Information Reporting Requirements

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This Alert covers updates from the Financial Crimes Enforcement Network (FinCEN) regarding Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements resuming. In light of the federal Court...more

Lowenstein Sandler LLP

Lump of Coal in the CTA Stocking: Texas Federal Court of Appeals Stays Injunction Against Corporate Transparency Act

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The U.S. Court of Appeals for the Fifth Circuit has granted the government’s motion to stay the Eastern District of Texas’ December 3 nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act...more

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – July to September 2024

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Welcome to the third Regulatory & Risk Advisory Review instalment of 2024. In this edition we cover the latest Cayman Islands regulatory updates including the Beneficial Ownership Transparency Act and The Perpetuities...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

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Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

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Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

Ballard Spahr LLP

Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

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First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

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