News & Analysis as of

Reporting Requirements Regulatory Reform Anti-Money Laundering

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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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

Snell & Wilmer

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

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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

K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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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

Morrison & Foerster LLP

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

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

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

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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

Herbert Smith Freehills Kramer

AML/CTF reforms: Rules take shape with further Consultation

A quick recap on reforms affecting reporting entities The Amended AML/CTF Act removed the concept of "designated business groups" and replaced this with "reporting group". The concept of "reporting group" means that, if...more

Tarter Krinsky & Drogin LLP

Changes to The Corporate Transparency Act Bring Major Shift to U.S. Reporting Requirements

Domestic Entities No Longer Required to Disclose Beneficial Ownership Information - The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule on March 21, 2025 (effective...more

Adams & Reese

CTA Reporting No Longer Required by U.S. Domestic Companies; Foreign Companies Only, Says FinCEN

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U.S. companies can exhale. All entities created in the U.S. – including those previously known as “domestic reporting companies” and their beneficial owners – will be exempt from Corporate Transparency Act (CTA) reporting...more

Lasher Holzapfel Sperry & Ebberson PLLC

FINCEN Filings Terminated

Per the U.S. Treasury Department announcement below, FinCEN is now dead except for some limited foreign entity reporting. Despite the many turbulent things happening in the U.S. government right now, this still came out of...more

Epstein Becker & Green

CTA Enforcement Halted Again: Treasury Department Suspends CTA Requirements for Domestic Reporting Companies

In yet another update to the ongoing saga of the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN), the agency of the U.S. Department of the Treasury (“Treasury Department”) that enforces the...more

Stoel Rives LLP

Corporate Transparency Act – Enforcement Suspended Until Further Notice

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or otherwise take any enforcement actions based on any failure to file or update...more

Warner Norcross + Judd

CTA Filing Obligations Back in Effect, but Further Developments Expected

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After weeks of legal ping-pong, the Corporate Transparency Act (CTA) reporting obligations are back in effect. On Feb. 18, 2025, the U.S. District Court for the Eastern District of Texas lifted its nationwide injunction in...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Ballard Spahr LLP

New York State’s LLC Transparency Act to Complement the Federal CTA

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New York State’s LLC Transparency Act, that will come into effect December 21, 2024, complements the Federal Corporate Transparency Act by requiring New York limited liability companies and foreign limited liability companies...more

Conyers

Bermuda Regulatory Outlook 2024

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As we enter 2024 the myriad of regulatory changes can appear overwhelming. We are here to help and have set out below some key changes and issues that can impact Bermuda entities. Bermuda has introduced a corporate income tax...more

Best Best & Krieger LLP

What You Need to Know About the U.S. Corporate Transparency Act

Practical Issues for Entity Management - The Corporate Transparency Act (CTA) is new legislation passed by Congress as part of the Anti-Money Laundering Act of 2020. This legislation sets forth uniform beneficial ownership...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

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