News & Analysis as of

FinCEN Proposed Rules Compliance

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... more +
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 -
BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

Chambliss, Bahner & Stophel, P.C.

Treasury Department Will Not Enforce Corporate Transparency Act Against U.S. Businesses

After months of uncertainty, legal challenges, and changing deadlines under the Corporate Transparency Act (CTA), the Treasury Department issued a press release on March 2, 2025, stating that it would not enforce any...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

Tonkon Torp LLP

The Corporate Transparency Act – Penalties Suspended

Tonkon Torp LLP on

The Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement action for failing to file or update BOI reports by the current...more

Vinson & Elkins LLP

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

Vinson & Elkins LLP on

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

Allen Matkins

Navigating the Changing Landscape of Corporate Transparency Act Compliance

Allen Matkins on

Both the U.S. Department of the Treasury and FinCEN, a bureau within the Treasury Department, have issued statements, which, taken together, indicate a significant reduction in the enforcement of the Corporate Transparency...more

Weintraub Tobin

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

Weintraub Tobin on

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

Kerr Russell

U.S. Treasury Will Not Enforce Current BOI Reporting Deadlines Under Corporate Transparency Act

Kerr Russell on

On March 2, 2025, the U.S. Department of Treasury announced that it will not enforce any penalties or fines associated with beneficial ownership information reports (BOI Reports) under the Corporate Transparency Act (CTA)....more

Lowenstein Sandler LLP

FinCEN Announces No Fines or Penalties Under the CTA Pending New Rulemaking, New Narrowed Enforcement Scope

As discussed in our prior client alert, following the February 18 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Dep’t of Treasury to stay a nationwide injunction it previously entered...more

Proskauer Rose LLP

Treasury Announces Non-Enforcement of the Corporate Transparency Act for Domestic Entities

Proskauer Rose LLP on

On March 2, 2025, the U.S. Department of the Treasury issued a press release announcing that it would not enforce any penalties or fines or take other enforcement actions against U.S. citizens or domestic reporting companies...more

Foley & Lardner LLP

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

Foley & Lardner LLP on

The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

Ruder Ware on

The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic...more

McGlinchey Stafford

Treasury Suspends CTA BOI Reporting Penalties for U.S. Companies, Individuals

McGlinchey Stafford on

On Sunday, March 2, 2025, the U.S. Department of Treasury announced, with respect to the Corporate Transparency Act (CTA), that it will not enforce penalties or fines for beneficial ownership information (BOI) reporting...more

Cole Schotz

CTA is Effectively on Pause (Again)

Cole Schotz on

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

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

Snell & Wilmer on

In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

ArentFox Schiff

The CTA: Now You See It … Now You Don’t

ArentFox Schiff on

As the flurry of Corporate Transparency Act (CTA) developments continues, on March 2, the US Department of the Treasury (Treasury) announced the suspension of CTA enforcement against US citizens and domestic reporting...more

Hinshaw & Culbertson LLP

UPDATE: FinCEN Pauses Penalties for CTA Reporting Noncompliance and Signals Additional Changes

As discussed in our previous alert, in connection with the recent reinstatement of the Corporate Transparency Act (CTA) and its reporting obligations, FinCEN issued an announcement (the "Prior Announcement") extending the...more

Foley & Lardner LLP

FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines for Now

Foley & Lardner LLP on

FinCEN announced that 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 beneficial ownership information (BOI) reports pursuant to the...more

Morris, Manning & Martin, LLP

FinCEN Announces Deadline Extension and Enforcement Pause

The ongoing saga of the Corporate Transparency Act (CTA) continues! On the evening of February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced three key developments. What Does This Mean for Your...more

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

BCLP on

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

Latham & Watkins LLP on

On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's July 2024 Round-Up

Holtzman Vogel attorneys wrote on the Supreme Court's landmark Loper Bright decision earlier this month. The Court overruled its 1984 decision in Chevron v. NRDC that introduced the so-called "Chevron deference" principle...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Holland & Knight LLP

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more

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