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National Security Compliance FinCEN

Faegre Drinker Biddle & Reath LLP

The Wallet Inspectors: The DPRK’s Sophisticated Campaign to Steal Cryptocurrency and How to Protect Yourself

On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens.  This attack marked a new pinnacle in the...more

Verrill

NEED MORE COWBELL: FinCEN Not Satisfied with Current Deadlines and Requirements under the Corporate Transparency Act

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On February 27, 2025, FinCEN issued a press release announcing future changes but giving no guidance about the scope of those changes: “No later than March 21, 2025, FinCEN intends to issue an interim final rule that...more

Foley Hoag LLP

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

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On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...more

Amundsen Davis LLC

The Corporate Transparency Act Is Back in Effect With a March 21 Reporting Deadline

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in a February 19, 2025 alert that the Corporate Transparency Act (CTA) is back in effect. The new deadline for most companies to...more

Nelson Mullins Riley & Scarborough LLP

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

McGlinchey Stafford

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

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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

Lathrop GPM

Six-Step Quick Guide to the Beneficial Ownership Information (“BOI”) Reporting Rules of the Corporate Transparency Act (“CTA”)

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In September 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final beneficial ownership information (“BOI”) reporting rules (the “BOI Reporting Rules”) of the Corporate...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

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On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

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Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Eversheds Sutherland (US) LLP

The Corporate Transparency Act is unconstitutional - For some, and for now

On March 1, 2024, the United States District Court for the Northern District of Alabama found that the Corporate Transparency Act (CTA) is unconstitutional because it exceeds Congress’ legislative power. The 53-page opinion...more

Mayer Brown

Federal Court Declares the Corporate Transparency Act Unconstitutional

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On March 1, 2024, the US District Court for the Northern District of Alabama declared the Corporate Transparency Act (“CTA”) unconstitutional, and suspended its enforcement against the plaintiffs in that case. While most...more

Baker Donelson

Alabama Federal Court Finds Corporate Transparency Act Unconstitutional

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The United States District Court for the Northern District of Alabama (Northeastern Division) held the Corporate Transparency Act (herein the CTA) to be unconstitutional. This decision, which came out on March 1, 2024, is...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

ArentFox Schiff

Non-US Companies Face New Compliance Requirements Under the US Corporate Transparency Act Beginning in 2024

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The Corporate Transparency Act (CTA) became effective on January 1. The CTA creates a new national database of companies, maintained by the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), to...more

Saiber LLC

The Corporate Transparency Act: Are You Prepared?

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Beginning on January 1, 2024, millions of business entities (including corporations, limited liability companies, and other similar entities created in or registered to do business in the United States) will be required to...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Womble Bond Dickinson

Explaining the New Corporate Transparency Act

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Beginning January 1, 2024, domestic entities and foreign entities registered to do business in the United States will need to comply with new information reporting requirements relating to their owners, officers, and...more

BakerHostetler

Corporate Transparency Act: An Overview

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What is the Corporate Transparency Act? The CTA will require all “reporting companies” to disclose certain information on their beneficial owners to FinCEN....more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Seward & Kissel LLP

Tri-Seal Compliance Note Encourages Voluntary Self-Disclosure of Potential Violations of Sanctions and Export Control Laws to DOJ,...

Seward & Kissel LLP on

The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Parker Poe Adams & Bernstein LLP

New Reporting Requirements Under the Corporate Transparency Act

The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued final regulations to implement the reporting requirements under the federal Corporate Transparency Act (CTA). The CTA aims to further...more

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