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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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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