News & Analysis as of August 3, 2025

Compliance

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

US Corporate Governance — 2025 Midyear Review

Herbert Smith Freehills Kramer on 7/8/2025

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

10 Important Facts About FinCEN’s Whistleblower Program

Oberheiden P.C. on 5/13/2025

The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

FinCEN Beneficial Ownership Reporting No Longer Required for all U.S. Companies

Mitchell, Williams, Selig, Gates & Woodyard,... on 3/25/2025

After months of uncertainty regarding enforcement of beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA), Financial Crimes Enforcement Network (FinCEN) has issued new rules...more

Corporate Transparency Act Enforcement Suspended Once Again!

Ward and Smith, P.A. on 3/14/2025

In a press release, Treasury officials confirmed they would not impose fines on U.S. citizens or domestic reporting companies, effectively pausing the reporting obligations for the time being. Under the original CTA...more

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

Holland & Hart LLP on 3/12/2025

After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

Is it Too Soon for a BOI Report Obituary?

Allen Barron, Inc. on 3/11/2025

Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....more

FINCEN Filings Terminated

Lasher Holzapfel Sperry & Ebberson PLLC on 3/11/2025

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

Weintraub Tobin on 3/7/2025

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related...more

BOI Reporting Penalties Suspended, No Need to File? Not So Fast

McGlinchey Stafford on 3/6/2025

The U.S. Department of Treasury has suspended all penalties and fines for beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. If...more

Breaking News: Corporate Transparency Act - Filing Deadlines Can Be Ignored for Now and Maybe Forever for Some

Shipman & Goodwin LLP on 3/5/2025

The Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) has changed the rules once again on the Corporate Transparency Act (CTA). Despite recently announcing that the new filing deadline for...more

Corporate Transparency Act Update: CTA MAY NOT APPLY to Domestic Entities After New Rule

Greenbaum, Rowe, Smith & Davis LLP on 3/4/2025

Last week, we reported that the U.S. Department of Treasury (DOT) through the Financial Crimes Enforcement Network (FinCEN) is temporarily staying enforcement of the monetary penalties for failure to comply with the Corporate...more

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

Buckingham, Doolittle & Burroughs, LLC on 3/3/2025

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or other enforcement actions against companies for failing to file or update beneficial ownership...more

Latest Update on Corporate Transparency Act Compliance: FinCEN Suspends Penalties for Failure to Report by Current Deadlines

Greenbaum, Rowe, Smith & Davis LLP on 3/3/2025

In our most recent Alert on the highly controversial and largely litigated nature of the Corporate Transparency Act (CTA), we reported that the CTA was back in effect nationwide and that, but for a few exceptions, all...more

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on 2/28/2025

On February 27, 2025, FinCEN announced “it will not issue any fines or penalties or take any other enforcement actions against companies based on any failure to file or update beneficial ownership information (BOI) reports...more

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

Greenbaum, Rowe, Smith & Davis LLP on 2/27/2025

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Corporate Transparency Act Update: FinCEN Extends Reporting Deadline for Companies

Weintraub Tobin on 2/26/2025

On February 18, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice extending the deadline for reporting companies to file their Beneficial Ownership Information (BOI) reports under the Corporate...more

Corporate Transparency Act Enforceable Again

Ward and Smith, P.A. on 2/25/2025

Accordingly, the new deadline to file an initial, updated, or corrected BOI report is now March 21, 2025. However, reporting companies that were previously given a reporting deadline later than the March 21, 2025, deadline...more

New Deadlines for FINCEN Compliance Issued

Haynsworth Sinkler Boyd, P.A. on 2/24/2025

The Corporate Transparency Act (CTA) introduced substantial new reporting obligations for a wide array of corporate entities. Generally, any domestic entity formed by filing documents with a secretary of state or similar...more

Corporate Transparency Act Updates - February 2025

Flaster Greenberg PC on 2/24/2025

On February 18, a federal court lifted the remaining injunction blocking enforcement of the Corporate Transparency Act (“CTA”), previously discussed. In response, FinCEN has stated that the reporting deadline for existing...more

BOI Reporting Requirements are Back in Force as of 2/18/2025

Allen Barron, Inc. on 2/20/2025

Attention: FinCEN BOI reporting requirement deadline is now set for March 21, 2025. A decision yesterday, February 18, 2025, in the case of Smith, et al. v. U.S. Department of Treasury, et al., 6:24-cv-00336, has returned...more

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

Kerr Russell on 2/11/2025

While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Corporate Transparency Act Updates

Flaster Greenberg PC on 2/10/2025

(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

Corporate Transparency Act Update As of January 23, 2025

Flaster Greenberg PC on 2/5/2025

Despite a Supreme Court ruling on January 23, there have been no material changes regarding Corporate Transparency Act (“CTA”) filing obligations. As of January 23, current FinCEN guidance is that no entity is required to...more

Crypto Executive Order: A New Era for Digital Assets

Paul Hastings LLP on 1/31/2025

President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

Amundsen Davis LLC on 1/28/2025

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

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