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On March 26, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an interim final rule which narrows the scope of existing beneficial ownership reporting requirements under the...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 17, 2025, the U.S. District Court for the Eastern District of Texas, in Smith et al. v. U.S. Department of the Treasury et al., stayed (lifted) the injunction blocking the enforcement of the Corporate Transparency...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 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 we near the end of 2024, it’s crucial to be aware of an important deadline under the Corporate Transparency Act (CTA). Reporting companies formed before January 1, 2024, must file their initial Beneficial Ownership...more
The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 3) Regulations 2024 have been published. The Regulations bring into force certain provisions of the Economic Crime and Corporate Transparency Act 2023....more
The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources. Key developments: - US Supreme Court...more
On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more
The federal Corporate Transparency Act (CTA) became effective on January 1, 2024, and despite multiple challenges and ongoing court cases, the CTA remains in effect. The CTA requires many entities to file beneficial ownership...more
Companies House has been granted new powers to crack down on fraud, but whether it has the resources to take advantage of these and properly clean up the register of companies is questionable. Originally published by...more
On 26 October 2023, the Economic Crime and Corporate Transparency Act 2023 (the Act) became law in the UK. The Act represents a major overhaul of the UK government’s framework for tackling financial crime and has brought into...more
Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more
The UK government is already proposing further expansion to the basis on which companies can be fixed with criminal liability. The Economic Crime and Corporate Transparency Act 2023 (ECCTA), passed in October, significantly...more
November 29, 2023 Update: In the ever-evolving world of the Corporate Transparency Act (the CTA), there was good news from the Treasury Department today. Reporting Companies formed on or after January 1, 2024, will have...more
The long-awaited Economic Crime and Corporate Transparency Act received Royal Assent on 26 October. This represents a significant turning point for the law on corporate criminal liability in the UK, and has been welcomed by...more
CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more
The Situation: After a year of debate, the Economic Crime and Corporate Transparency Act (the "Act") was passed into law on 26 October 2023....more
The new Economic Crime and Corporate Transparency Act 2023 (the Act) is the latest step in the UK Government’s attempts to address economic crime and improve transparency over corporate entities. Whilst most of the key...more
The Economic Crime and Corporate Transparency Act 2023 was granted Royal Assent on 26 October 2023. It contains a new ‘failure to prevent fraud’ corporate criminal offence which will render large companies liable for fraud...more
The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”). They pertain, in part, to a proposed extension of the filing deadline for certain...more
The Financial Crimes Enforcement Network (“FinCEN”) is proposing to amend the beneficial ownership information (“BOI”) reporting rule (the “Reporting Rule”) to extend the filing deadline for certain companies to file their...more
Presently, forming a corporation, LLC, or other entity in the U.S. can be done on a largely anonymous basis, without naming its owners and with only limited disclosures about managers, officers, and directors. Under the...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more