News & Analysis as of July 30, 2025

Regulatory Reform

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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 Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on 7/29/2025

Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

King & Spalding on 7/25/2025

Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on 7/25/2025

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on 7/25/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on 7/24/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

United States: AML Reprieve for Investment Advisers

K&L Gates LLP on 7/23/2025

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

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on 7/23/2025

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

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

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on 7/10/2025

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

Cozen O'Connor on 6/24/2025

As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the CTA

Husch Blackwell LLP on 4/9/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) removing the requirement for U.S. domestic reporting companies and U.S. persons to report Beneficial Ownership...more

On Again, Off Again: FinCEN's New Interim Final Rule on the Corporate Transparency Act – U.S. Entities and Citizens Exempt from...

Lowndes on 4/3/2025

Anyone who has followed the on-again, off-again history of the Corporate Transparency Act’s (CTA) Beneficial Owner Information (BOI) reporting requirements will not be surprised that, effective March 26, the Financial Crimes...more

FinCEN Exempts All Entities Created in the U.S. From the Corporate Transparency Act (CTA)

Ballard Spahr LLP on 3/27/2025

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an Alert stating that all entities created in the U.S.—including those previously known as “domestic reporting companies”—and their beneficial owners...more

Scope of Corporate Transparency Act Dramatically Narrowed Under New Rule

Parker Poe Adams & Bernstein LLP on 3/27/2025

In an interim final rule (IFR) announced March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) dramatically narrowed the scope of the Corporate Transparency Act (CTA). Under the IFR, which is effective...more

New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

Proskauer Rose LLP on 3/27/2025

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

FinCEN Eliminates BOI Reporting for U.S. Companies and U.S. Persons

Morris, Manning & Martin, LLP on 3/26/2025

The Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule significantly narrowing the scope of the Corporate Transparency Act (CTA) by removing the requirement for U.S. companies and U.S. persons to...more

Update: U.S. Companies and U.S. Persons No Longer Required to Provide Beneficial Ownership Information under the Corporate...

Seward & Kissel LLP on 3/26/2025

Following the Treasury Department’s announcement regarding the removal of fines and penalties under the Corporate Transparency Act (“CTA”), the Financial Crimes Enforcement Network (“FinCEN”) has now advised that U.S....more

CTA Reporting Relief: FinCEN Interim Rule Exempts US Companies from Reporting Beneficial Ownership & Foreign Companies from...

Moore & Van Allen PLLC on 3/25/2025

The Financial Crimes and Enforcement Network of the U.S. Treasury Department (FinCEN) on March 21, 2025 announced an interim final rule (the “Interim Rule”) which, if finalized in its current form, exempts all domestic...more

CTA is No Longer Applicable to U.S. Entities and U.S. Persons; Foreign Entities Face New Rules

Cole Schotz on 3/25/2025

On Friday, March 21, 2025, FinCEN announced an interim rule that removed Beneficial Ownership (“BOI”) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act (the “CTA”). FinCEN’s new...more

Corporate Transparency Act Update - FinCEN Interim Rule

Flaster Greenberg PC on 3/25/2025

On March 21, FinCEN issued an interim rule that implements the reduced scope of the Corporate Transparency Act (“CTA”) previously announced on March 2....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

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

Bracewell LLP on 3/13/2025

If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...more

CTA Reporting and Enforcement Suspended Indefinitely

Clark Hill PLC on 3/10/2025

In a whirlwind series of announcements, the Treasury Department and FinCEN have suspended all Corporate Transparency Act (CTA) reporting and enforcement for domestic entities indefinitely. On Feb. 27, FinCEN announced that...more

Treasury suspends enforcement of beneficial ownership information reporting for U.S. companies, focuses on foreign entities

Orrick, Herrington & Sutcliffe LLP on 3/10/2025

On March 2, the Treasury announced it will suspend enforcement of fines or penalties indefinitely for beneficial ownership information (BOI) reporting. This suspension of enforcement will be for U.S. domestic reporting...more

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