News & Analysis as of

FinCEN Regulatory Requirements Financial Regulatory Reform

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

K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

Troutman Pepper Locke on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Troutman Pepper Locke

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

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The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...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

Pullman & Comley, LLC

FinCEN Eliminates BOI Reporting for U.S. Companies under the Corporate Transparency Act

Pullman & Comley, LLC on

On March 21, 2025 FinCEN published an interim final rule that eliminates “beneficial ownership information” (BOI) reporting requirements for all domestic companies. ...more

Woods Rogers

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

Woods Rogers on

Consistent with the Treasury Department’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule on March 21, 2025 that removes the requirement for U.S. companies and U.S....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

Neal, Gerber & Eisenberg LLP

Treasury Limits CTA Enforcement to Foreign Companies

On March 2, 2025, the Treasury Department expanded the scope of FinCEN’s February 27, 2025 statement that it will not enforce any penalties or fines under the Corporate Transparency Act with respect to existing regulatory...more

Cole Schotz

CTA Is In Effect, For Now

Cole Schotz on

As of today, the Corporate Transparency Act (the “CTA”) is back in effect, with the deadline to file Beneficial Ownership Information (“BOI”) extended to March 21, 2025 for those entities that are not exempt from filing....more

Troutman Pepper Locke

FDIC Acting Chairman Hill Supports Modernizing Customer Identification Program Requirements

Troutman Pepper Locke on

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer...more

Paul Hastings LLP

State Stablecoin Legislation

Paul Hastings LLP on

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

Neal, Gerber & Eisenberg LLP

CTA Remains on Hold Despite Supreme Court Ruling

The Corporate Transparency Act (CTA) remains on hold despite a recent Supreme Court ruling. On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that had been issued by a...more

Carey Olsen

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

Carey Olsen on

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

Brooks Pierce

Corporate Transparency Act: Texas Injunction Stays Enforcement of CTA

Brooks Pierce on

On Tuesday, December 3, 2024, a United States district court in the Eastern District of Texas issued a national preliminary injunction enjoining the enforcement of the Corporate Transparency Act. The injunction specifically...more

Epstein Becker & Green

Corporate Transparency Act’s January 1, 2025, Deadline Looms for Reporting Companies Existing Prior to 2024

Epstein Becker & Green on

The reporting requirements of the Corporate Transparency Act (CTA), included as part of the Anti-Money Laundering Act of 2020, went into effect on January 1, 2024, and certain deadlines of January 1, 2025, are fast...more

Verrill

Filing a BOI Report Online: A Step-by-Step Guide

Verrill on

Navigating the process of filing Beneficial Ownership Information (BOI) reports can be challenging. That's why we've created a comprehensive guide to help you through the technical steps of completing your online BOI...more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

Seyfarth Shaw LLP on

On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Burr & Forman

Corporate Transparency Act Filing Deadlines Approaching - What You Need to Know, Part I

Burr & Forman on

The Corporate Transparency Act (CTA) requires “reporting companies” to report certain beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in order to enhance...more

Stradling Yocca Carlson & Rauth

Navigating the Complexities of CTA Compliance: What You Need to Know

On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule to implement beneficial ownership reporting requirements set forth in the Corporate Transparency Act (the “CTA”).   The CTA...more

Jenner & Block

FinTech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

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Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more

Stinson LLP

The Final Countdown: Major CTA Reporting Deadline Rapidly Approaching

Stinson LLP on

Barring any unforeseen changes, the Corporate Transparency Act's (CTA) major reporting deadline arrives on January 1, 2025. The CTA requires all existing reporting companies (those entities formed prior to January 1, 2024) to...more

Conyers

Shifting Sands: The Future of Offshore Regulatory Disputes (Part 1)

Conyers on

As an evolving area of commercial disputes in the Cayman Islands, global enforcement trends provide us with valuable insight into the types of regulatory proceedings on the horizon for offshore jurisdictions. In this first...more

Faegre Drinker Biddle & Reath LLP

Entities That 'Cease to Exist' Must Still Comply With the Corporate Transparency Act

On Monday, July 8, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released additional FAQs specifying that a reporting company (i.e., a company to which no exemption applies) created or...more

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