News & Analysis as of July 25, 2025

Reporting Requirements

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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 -

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on 7/22/2025

On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

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

Procopio, Cory, Hargreaves & Savitch LLP on 5/20/2025

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

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

Understanding FinCEN’s Southwest Border Geographic Targeting Order for Money Service Businesses

IR Global on 4/23/2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Southwest Border Geographic Targeting Order (GTO) aimed at Money Service Businesses (MSBs)[1]. This order is designed to enhance the monitoring and...more

New Reporting Requirement for Certain Residential Real Estate Transfers

Harris Beach Murtha PLLC on 4/21/2025

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

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

Greenberg Glusker LLP on 4/16/2025

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

The (Almost) End of the Corporate Transparency Act

Snell & Wilmer on 4/14/2025

In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

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

IR Global on 4/11/2025

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

Client Alert: Financial Crimes Enforcement Network (FinCEN) Removes Beneficial Ownership Reporting Requirements for U.S. Companies...

Shumaker, Loop & Kendrick, LLP on 4/2/2025

On March 26, 2025, FinCEN announced that “All entities created in the United States – including those previously known as ‘domestic reporting companies’ – and their beneficial owners are now exempt from the requirement to...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: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

Brooks Pierce on 3/21/2025

Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on 3/18/2025

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

FinCEN Joins the Government-Wide Pursuit of Cartels

Morrison & Foerster LLP on 3/17/2025

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...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

FinCEN To Suspend CTA Enforcement, Extend BOI Reporting Deadlines

BakerHostetler on 3/3/2025

Continuing on its roller coaster of the past few months, CTA compliance is effectively back on hold after FinCEN announced that it plans to further extend the existing reporting deadlines. Below, we address some of the key...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

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