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Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Friling Law

Legal Guidance for Financial Integrity and Whistleblower Protection

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Over the past few years, whistleblowers have become a driving force in uncovering financial misconduct in the U.S. Individuals may report illicit financial activity, including money laundering, sanctions evasion, fraud, and...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – May 2025

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

DLA Piper

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

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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

Katten Muchin Rosenman LLP

Breaking News: Fifth Circuit Court of Appeals Stays Nationwide Preliminary Injunction Enjoining Enforcement of the Corporate...

Update: As of December 23, 2024, and until FinCEN issues updated guidance, the CTA reporting deadlines remain in effect (including January 1, 2025, for non-exempt Reporting Companies created prior to January 1, 2024)....more

Shumaker, Loop & Kendrick, LLP

Client Alert: FinCEN's Formal Position on the Corporate Transparency Act Nationwide Injunction

On December 9, the Financial Crimes Enforcement Network (FinCEN) released its official position on the preliminary injunction of the Corporate Transparency Act (CTA), issued on December 3, 2024, by the U.S. District Court of...more

Katten Muchin Rosenman LLP

Breaking News: Federal District Court Halts Corporate Transparency Act Enforcement Nationwide

This Corporate Advisory provides a brief update on recent litigation regarding the Corporate Transparency Act (CTA) and its reporting requirements. It is not intended to, and does not, provide legal, compliance or other...more

Epstein Becker & Green

Corporate Transparency Act’s January 1, 2025, Deadline Looms for Reporting Companies Existing Prior to 2024

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The reporting requirements of the Corporate Transparency Act (CTA), included as part of the Anti-Money Laundering Act of 2020, went into effect on January 1, 2024, and certain deadlines of January 1, 2025, are fast...more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

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On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Burr & Forman

Corporate Transparency Act Filing Deadlines Approaching - What You Need to Know, Part I

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The Corporate Transparency Act (CTA) requires “reporting companies” to report certain beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in order to enhance...more

Wilson Sonsini Goodrich & Rosati

Important Filing Deadline: The U.S. Corporate Transparency Act

As we approach the final quarter of 2024, we wanted to remind you of the rapidly approaching deadline for the new Beneficial Ownership Information (BOI) reporting requirements under the U.S. Corporate Transparency Act (CTA)....more

Stradling Yocca Carlson & Rauth

Navigating the Complexities of CTA Compliance: What You Need to Know

On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule to implement beneficial ownership reporting requirements set forth in the Corporate Transparency Act (the “CTA”).   The CTA...more

Stinson LLP

The Final Countdown: Major CTA Reporting Deadline Rapidly Approaching

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Barring any unforeseen changes, the Corporate Transparency Act's (CTA) major reporting deadline arrives on January 1, 2025. The CTA requires all existing reporting companies (those entities formed prior to January 1, 2024) to...more

Conyers

Shifting Sands: The Future of Offshore Regulatory Disputes (Part 1)

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As an evolving area of commercial disputes in the Cayman Islands, global enforcement trends provide us with valuable insight into the types of regulatory proceedings on the horizon for offshore jurisdictions. In this first...more

Jones Day

FinCEN Clarifies Application of Beneficial Ownership Reporting Rules to Dissolved Entities

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Reporting companies should take note of a recent clarification by the Financial Crimes Enforcement Network ("FinCEN") that the Beneficial Ownership Information ("BOI") Rule requires reporting companies that exist on or after...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...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

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Ballard Spahr LLP

FinCEN Proposes Rule to Enhance AML/CFT Programs Across Industries

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FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more

Faegre Drinker Biddle & Reath LLP

Entities That 'Cease to Exist' Must Still Comply With the Corporate Transparency Act

On Monday, July 8, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released additional FAQs specifying that a reporting company (i.e., a company to which no exemption applies) created or...more

Troutman Pepper Locke

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Carlton Fields

Regulators Seek to Saddle Industry With New Obligations: Firms Bridle and Stir Up Opposition

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The Financial Crimes Enforcement Network (FinCEN), the Commodity Futures Trading Commission (CFTC), and the SEC have adopted or are proposing substantial increases in regulation of industry participants, primarily investment...more

Cadwalader, Wickersham & Taft LLP

Challenges to the Corporate Transparency Act

The Corporate Transparency Act (the “CTA”), which became effective on January 1, 2024, requires certain domestic and foreign companies doing business in the United States to file a beneficial ownership report with the U.S....more

Troutman Pepper Locke

FinCEN Proposes Loosening Customer Identification Program Requirements

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On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more

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