News & Analysis as of August 10, 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 -

A Continuing Saga of CTA Uncertainty

Otten Johnson Robinson Neff + Ragonetti PC on 3/18/2025

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

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

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

Miller Canfield on 3/5/2025

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

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

White and Williams LLP on 3/4/2025

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

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

Shipkevich PLLC on 3/4/2025

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

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

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

Perkins Coie on 3/3/2025

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

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

Keating Muething & Klekamp PLL on 3/3/2025

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

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

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

Shipkevich PLLC on 2/25/2025

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

Corporate Transparency Act – BOI Report Filings Mandatory Again

Tonkon Torp LLP on 2/24/2025

On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued an Order in the Smith case lifting the preliminary injunction against enforcement of the CTA. Therefore, BOI Report filings are once again...more

The CTA Strikes Back

ArentFox Schiff on 2/21/2025

Following a cascade of developments, the Corporate Transparency Act (CTA) is back, but with some potential changes on the horizon. Most reporting companies that have not yet filed all required reports under the CTA should...more

Latest CTA Injunction Stayed

Cozen O'Connor on 2/21/2025

On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more

CTA Enforcement Reinstated with New Compliance Deadlines

Kerr Russell on 2/20/2025

The U.S. District Court for the Eastern District of Texas has stayed the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Smith v. U.S. Department of the Treasury....more

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

McGlinchey Stafford on 2/20/2025

As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

State Stablecoin Legislation

Paul Hastings LLP on 2/10/2025

Stablecoins, which are digital assets pegged to fiat currency or other assets, play a crucial role in crypto markets, offering price stability and facilitating transactions. Despite their growing significance, there is no...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

Crypto Quarterly Digital Assets, Blockchain and Related Technologies Update

Ropes & Gray LLP on 1/28/2025

The landscape of government enforcement, private litigation and federal and state regulation of digital assets, blockchain and related technologies is constantly evolving. Each quarter, Ropes & Gray attorneys analyze...more

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

McGlinchey Stafford on 1/27/2025

The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more

Livin’ on a Stay: The CTA Saga Continues

Ruder Ware on 1/24/2025

The Corporate Transparency Act (“CTA”) and its beneficial ownership reporting requirements are back in effect. Earlier today, the U.S. Supreme Court granted the federal government’s request to stay (i.e., pause) the...more

State-Level Developments: The Regulatory Landscape for Digital Assets

Paul Hastings LLP on 1/13/2025

As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

GLI British Virgin Islands blockchain and cryptocurrency regulation 2025, seventh edition

Carey Olsen on 1/8/2025

Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

Update zum US-Transparenzregister

McDermott Will & Schulte on 12/4/2024

Handlungsbedarf für Unternehmen bis Jahresende - Nachdem das Transparenzregister in Deutschland und Europa inzwischen seit einigen Jahren existiert und dessen Meldepflichten in der Praxis umfassend beachtet werden, gibt...more

Corporate Transparency Act: Client Alert Update

Sullivan & Worcester on 12/3/2024

As we enter December, the deadline for existing non-exempt entities to comply with the Corporate Transparency Act (CTA) is fast approaching. Entities that were formed or registered to do business in the United States prior to...more

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