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U.S. Treasury Rulemaking Process Regulatory Requirements

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...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

Proskauer Rose LLP

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

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On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...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

Morrison & Foerster LLP

The GENIUS Act: A New Federal Regulatory Framework for Payment Stablecoins

On July 18, 2025, President Trump signed into law S. 1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or the “Act”). The Act covers payment stablecoins[1]—a relatively new form...more

Paul Hastings LLP

The GENIUS Act: A Comprehensive Guide to US Stablecoin Regulation

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Today marks a historic milestone in U.S. digital asset policy. The President signed the GENIUS Act into law following its bipartisan passage by 308-122 in the House on July 17 and 68-30 in the Senate on June 17. The GENIUS...more

Orrick, Herrington & Sutcliffe LLP

Treasury issues final rule to eliminate several regulations

On April 15, the Treasury issued a direct final rule to eliminate several regulations or portions of regulations it deemed unnecessary in response to an Executive Order 14219 directing agencies to pursue deregulation. The...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

Ropes & Gray LLP on

On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Brooks Pierce

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

Brooks Pierce on

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

Bracewell LLP

Another CTA Freeze: Treasury Department Announces Suspension of Enforcement Against Domestic Reporting Companies

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If you have been following our reports on the subject, you know that the Corporate Transparency Act (CTA) had a tumultuous end to 2024 and start to 2025, with a series of court actions leading to oscillating reports about...more

Warner Norcross + Judd

CTA Filing is Now Voluntary for US Entities and Citizens: Rule Changes Ahead

Warner Norcross + Judd on

The United States Treasury Department announced on March 2, 2025, that the Beneficial Ownership Information (BOI) reporting required by the Corporate Transparency Act (CTA) is now voluntary for U.S. entities and citizens....more

Downs Rachlin Martin PLLC

Corporate Transparency Act – U.S. Treasury Department Suspends Enforcement Against U.S. Citizens and Domestic Reporting Companies

The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their...more

Chambliss, Bahner & Stophel, P.C.

Treasury Department Will Not Enforce Corporate Transparency Act Against U.S. Businesses

After months of uncertainty, legal challenges, and changing deadlines under the Corporate Transparency Act (CTA), the Treasury Department issued a press release on March 2, 2025, stating that it would not enforce any...more

Katten Muchin Rosenman LLP

US Treasury Announces That the Corporate Transparency Act Will Not Be Enforced Against Domestic Companies, Their Beneficial Owners...

As noted in our previous Corporate Advisory, the Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025, that it will not take enforcement action against a Reporting Company that fails to file or update...more

Seward & Kissel LLP

Treasury Department Confirms: No Fines or Penalties in Connection with BOI Reporting Deadlines

Seward & Kissel LLP on

While the March 21, 2025 filing deadline under the Corporate Transparency Act (the “CTA”) remains in place, the Treasury Department announced on March 2nd that it will not enforce any penalties or fines associated with...more

Neal, Gerber & Eisenberg LLP

Treasury Limits CTA Enforcement to Foreign Companies

On March 2, 2025, the Treasury Department expanded the scope of FinCEN’s February 27, 2025 statement that it will not enforce any penalties or fines under the Corporate Transparency Act with respect to existing regulatory...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

Husch Blackwell LLP

U.S. Treasury Department Declines to Enforce CTA

Husch Blackwell LLP on

On March 2, 2025, the U.S. Department of the Treasury ended months of speculation regarding how the Corporate Transparency Act (CTA) would be implemented and enforced under the second Trump administration. Via press release,...more

BakerHostetler

New Treasury Statement Nullifies CTA for US Entities

BakerHostetler on

The CTA is not dead, but it is hanging by a thread. On March 2, the U.S. Treasury Department (the Treasury) issued a press release announcing significant updates to the plans announced by FinCEN just a few days earlier....more

Adams & Reese

Reverse Course – Treasury Department Announces No CTA Enforcement on U.S. Businesses

Adams & Reese on

Two weeks after FinCEN received the green light from the courts to proceed with enforcement of the Corporate Transparency Act, the U.S. Treasury Department has put the car in reverse....more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

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In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

Shipkevich PLLC

U.S. Treasury Department Announces Suspension of BOI Reporting Penalties for U.S. Parties

Shipkevich PLLC on

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

Eversheds Sutherland (US) LLP

SEC approves extension of Treasury clearing compliance dates

On Tuesday, February 25, 2025, the Securities and Exchange Commission (SEC) issued a one-year extension of the compliance dates for its clearing mandate for certain US Treasury cash and repurchase (repo) transactions, in...more

Dinsmore & Shohl LLP

FinCEN Will Not Enforce CTA Penalties and Intends to Further Extend Filing Deadlines

Dinsmore & Shohl LLP on

On February 27, 2025, FinCEN issued a news release stating that it will not impose fines or penalties for failure to file Beneficial Ownership Information (BOI) reports by the current deadlines. This follows FinCEN’s February...more

Kilpatrick

Corporate Transparency Act Suspended (Again)

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We recently reported that the Corporate Transparency Act (CTA) was back in effect due to the stay of the nationwide preliminary injunction previously entered in the case of Smith v. U.S. Department of the Treasury....more

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