News & Analysis as of

FinCEN Regulatory Agenda

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 -
Haynes Boone

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

Haynes Boone on

FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...more

BCLP

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

BCLP on

On July 17, 2025, Congress passed the Guiding and Establishing National Innovation for U.S Stablecoins Act (“GENIUS Act” or “Act”) – a landmark piece of legislation that received bipartisan support and was signed into law by...more

McDermott Will & Emery

IRS roundup: June 18 – July 11, 2025

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions - On July 4, 2025, US President Donald...more

Cadwalader, Wickersham & Taft LLP

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

Kelley Drye & Warren LLP

FinCEN Exempts Domestic Reporting Companies and Persons from CTA Reporting Requirements

On March 26, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an interim final rule which narrows the scope of existing beneficial ownership reporting requirements under the...more

Ballard Spahr LLP

Anti-Money Laundering Aspects of the GENIUS Act

Ballard Spahr LLP on

On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

McGlinchey Stafford on

Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Paul Hastings LLP

Latest Executive and Legislative Actions Continue Crypto-Friendly Movement

Paul Hastings LLP on

The past two weeks have been a whirlwind of activity for the financial and crypto sectors, with developments on Capitol Hill and from key regulatory agencies. President Donald Trump’s nomination of Michelle Bowman as the...more

Otten Johnson Robinson Neff + Ragonetti PC

A Continuing Saga of CTA Uncertainty

On February 27, 2025, FinCEN published guidance related to the Corporate Transparency Act (the “CTA”) taking the position that it would not “issue any fines or penalties or take any other enforcement actions against any...more

Ward and Smith, P.A.

Corporate Transparency Act Enforcement Suspended Once Again!

Ward and Smith, P.A. on

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

Verrill

Indefinite Suspension of CTA Filing Obligations (For Now)

Verrill on

On March 2, 2025 the U.S. Treasury Department laid waste to about a million law firm postings about the Corporate Transparency Act, announcing that Treasury now intends to propose fundamental changes to the CTA Rule and that...more

Woods Rogers

Treasury Department Suspends Enforcement of the Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies

Woods Rogers on

The U.S. Treasury Department has suspended enforcement of the Corporate Transparency Act for all U.S. citizens and domestic reporting companies. In a statement on March 2, 2025, the Treasury Department announced that it...more

Ballard Spahr LLP

Recent Developments Raise Significant Questions about the Future of Regulation and Enforcement of Cryptocurrency

Ballard Spahr LLP on

Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Announces Changes to the BOI Reporting Requirements Under the Corporate Transparency Act

On March 2, 2025, the Department of Treasury confirmed in a press release that it will not enforce any penalties or fines associated with the BOI reporting requirements under the existing regulatory deadlines...more

Miller Canfield

Treasury May Be Shifting CTA Reporting Rule Away from Domestic and Toward Foreign Reporting Companies

Miller Canfield on

On March 2, 2025, the United States Department of Treasury announced that it will not enforce fines or penalties based on the existing deadlines for reporting beneficial ownership information under the CTA beneficial...more

McGuireWoods LLP

Treasury Department Declares Intent to Limit CTA to Foreign Reporting Companies

McGuireWoods LLP on

After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Shipkevich PLLC

U.S. Treasury Department Announces Suspension of BOI Reporting Penalties for U.S. Parties

Shipkevich PLLC on

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that most reporting companies under the Corporate Transparency Act (“CTA”) must now submit their Beneficial Ownership Information (“BOI”)...more

Buckingham, Doolittle & Burroughs, LLC

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

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

Perkins Coie

Corporate Transparency Act: Filing Requirements Once Again Voluntary – FinCEN Announces No Enforcement Action for Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Will Not Enforce the CTA Until Interim Rule is Effective

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or initiate any other enforcement action against companies that do not file or update...more

Miller & Martin PLLC

The Corporate Transparency Act: FinCEN Not Issuing Fines or Penalties in Connection with March 21 Deadline

Miller & Martin PLLC on

As an update to our February 21 article, yesterday 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...more

McGlinchey Stafford

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on

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

Shumaker, Loop & Kendrick, LLP

Client Alert: Beneficial Ownership Information (BOI) Reporting Requirements are Back

On February 17, 2025, the U.S. District Court for the Eastern District of Texas, in Smith et al. v. U.S. Department of the Treasury et al., stayed (lifted) the injunction blocking the enforcement of the Corporate Transparency...more

Shipkevich PLLC

BOI Reporting Back in Effect: Compliance Required by March 21, 2025

Shipkevich PLLC on

On February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that most reporting companies under the Corporate Transparency Act (CTA) must now submit their Beneficial Ownership Information (BOI) reports...more

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