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An Introduction to DAFs and Overview of the Newly Proposed DAF Regulations
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Stablecoin Regulation in an Unstable Time: The Fed and Treasury Address a Stablecoin Regulatory Framework
New Regulation: Statutes, Pillars, and the Build Back Better Act
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U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial,...more
On April 1, 2025, the Texas Association for Money Service Businesses filed a lawsuit in San Antonio federal court challenging the recent Geographic Targeting Order (GTO) applicable to money services businesses (MSBs) located...more
How Did We Get Here? The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and was enacted as part of the Anti-Money Laundering Act of 2020....more
In a whirlwind series of announcements, the Treasury Department and FinCEN have suspended all Corporate Transparency Act (CTA) reporting and enforcement for domestic entities indefinitely. On Feb. 27, FinCEN announced that...more
On March 1, 2025, the U.S. Department of the Treasury announced that it will not enforce the Corporate Transparency Act (CTA) against U.S. citizens or domestic reporting companies or their beneficial owners. Treasury also...more
The U.S. Department of the Treasury announced on March 2, 2025 that it will not take any enforcement action against U.S. citizens and legal entities formed in the United States or their beneficial owners in connection with...more
On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more
U.S. citizens and domestic companies will no longer be subject to the CTA or its reporting requirements. Just under two weeks after the Financial Crimes Enforcement Network (FinCEN), an enforcement bureau within the U.S....more
On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury announced that it will not be issuing any fines or penalties or taking any other enforcement actions against any...more
What Happened? On February 18, 2025, the last of the nationwide injunctions enjoining enforcement of the Corporate Transparency Act (“CTA”), Smith, et al. v. U.S. Department of the Treasury, et al., (E.D. Tex.), was stayed,...more
In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens....more
In a press release issued on March 2, 2025, the United States Department of the Treasury announced that “with respect to the Corporate Transparency Act…[it will] not enforce any penalties or fines against U.S. citizens or...more
On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take any other enforcement actions against any companies based on a failure to file or...more
On March 2, 2025, the U.S. Treasury Department issued a press release announcing that, for now, the Department will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under...more
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
On January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) issued by a federal judge in Texas (Texas...more
The filing requirements under the Corporate Transparency Act (“CTA”) have once again been restored. In yet another reversal of the on again, off again saga, on February 18, 2025, the U.S. District Court for the Eastern...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
On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more
(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
A flurry of activity in the courts and guidance from FinCEN this week has the Corporate Transparency Act back in the news. However, the recent activity does not result in any immediate change for businesses. Filing beneficial...more
In an alert posted this morning, FinCEN has announced that reporting companies are not currently required to file beneficial ownership reports even with the U.S. Supreme Court’s order yesterday. Instead of issuing a new...more