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Hendershot Cowart P.C.

Qlarant, Novitas Audits Escalate as Medicare Skin Substitutes Spending Hits $1.6 Billion, CMS Seeks Evidence of Clinical...

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The wound care industry faces unprecedented scrutiny as Medicare Part B expenditures for skin substitutes exceeded $1.6 billion in the fourth quarter of 2023 alone. The spending surge has triggered a wave of skin substitute...more

McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Hogan Lovells

ESG Investigations in Europe Part I – Enforcement trends and particularities

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Recent years have seen an ever increasing density of ESG regulation on the national, European and global level. With significant regulations already or about to enter into force, enforcement actions on different levels,...more

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

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Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Ward and Smith, P.A.

Corporate Transparency Act Enforcement Suspended Once Again!

Ward and Smith, P.A. on

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

Holland & Hart LLP

The CTA Is Back (Sort Of)—What Reporting Companies Need to Know

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After months of litigation—including a cameo before the Supreme Court—the last nationwide injunction of the Corporate Transparency Act (CTA) was vacated and the CTA was set to go back into effect. Since then, nothing has been...more

Weintraub Tobin

Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule...

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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

McGlinchey Stafford

BOI Reporting Penalties Suspended, No Need to File? Not So Fast

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The U.S. Department of Treasury has suspended all penalties and fines for beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. If...more

Spilman Thomas & Battle, PLLC

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

After months of back-and-forth regarding the status of the Corporate Transparency Act (“CTA”), the U.S. Department of Treasury has effectively ended the CTA’s reporting obligations for U.S. citizens and domestic reporting...more

Greenbaum, Rowe, Smith & Davis LLP

Corporate Transparency Act Update: CTA MAY NOT APPLY to Domestic Entities After New Rule

Last week, we reported that the U.S. Department of Treasury (DOT) through the Financial Crimes Enforcement Network (FinCEN) is temporarily staying enforcement of the monetary penalties for failure to comply with the Corporate...more

Buckingham, Doolittle & Burroughs, LLC

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

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

Greenbaum, Rowe, Smith & Davis LLP

Latest Update on Corporate Transparency Act Compliance: FinCEN Suspends Penalties for Failure to Report by Current Deadlines

In our most recent Alert on the highly controversial and largely litigated nature of the Corporate Transparency Act (CTA), we reported that the CTA was back in effect nationwide and that, but for a few exceptions, all...more

Wilson Sonsini Goodrich & Rosati

Preparing for the 2025 Reporting Season: Proxy Season Reminders

With the 2025 proxy season upon us, this Alert highlights governance, disclosure, and engagement considerations for companies preparing for their 2025 annual meetings. Many of the governance and disclosure matters discussed...more

McGlinchey Stafford

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on

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

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Ward and Smith, P.A.

Corporate Transparency Act Enforceable Again

Ward and Smith, P.A. on

Accordingly, the new deadline to file an initial, updated, or corrected BOI report is now March 21, 2025.  However, reporting companies that were previously given a reporting deadline later than the March 21, 2025, deadline...more

Flaster Greenberg PC

Corporate Transparency Act Updates - February 2025

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On February 18, a federal court lifted the remaining injunction blocking enforcement of the Corporate Transparency Act (“CTA”), previously discussed. In response, FinCEN has stated that the reporting deadline for existing...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: Injuction Lifted - Corporate Transparency Act Back in Effect

On February 17, a federal judge in Texas lifted a preliminary injunction issued in Smith v. United States Department of the Treasury, removing the last legal hurdle to the enforcement of the Corporate Transparency Act...more

Ruder Ware

It’s Tricky! Tracking the CTA

Ruder Ware on

The Corporate Transparency Act (CTA) remains on hold due to a nationwide injunction granted by a federal District Court in Texas in Smith v. U.S. Department of the Treasury. However, given pending legal battles and...more

WilmerHale

Corporate Transparency Act: It’s Still Paused (For Now)

WilmerHale on

Entities subject to the Corporate Transparency Act’s beneficial ownership information reporting requirement are not currently required to file BOI reports. Beyond that, much remains in flux regarding whether and when...more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

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While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Flaster Greenberg PC

Corporate Transparency Act Updates

Flaster Greenberg PC on

(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...more

Spilman Thomas & Battle, PLLC

Corporate Transparency Act Still Blocked Despite Supreme Court Decision

The saga of confusing Corporate Transparency Act (CTA) litigation continues, but the guidance remains the same: companies are not currently obligated to file Beneficial Ownership Information (BOI) reports with the U.S....more

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