Adam J. Fleisher

Dec 14, 2023 | mondaq.com | Adam J. Fleisher |Jasmine Banks

The beneficial ownership information (BOI) reporting rule implementing Section 6403 of the Corporate Transparency Act (CTA) was finalized by the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) in September 2022. The BOI rule starts taking effect on January 1, 2024, and, as a general matter, sets a 30-day deadline for covered companies formed after January 1, 2024, to submit required reports.

Nov 17, 2023 | mondaq.com | Sean Ruff |Obrea Poindexter |Michelle Rogers |Adam J. Fleisher

On November 7, 2023, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (proposed rule) that would allow it to supervise digital wallet and payment app providers deemed "larger participants." The proposed rule would apply to nonbank payments companies that offer digital wallets or person-to-person payments through mobile and web applications, process more than five million covered payment transactions per year and are not a "small business concern," as...

Sep 22, 2023 | mondaq.com | Adam J. Fleisher

On September 18, 2023, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) published its Small Entity Compliance Guide – the agency's most comprehensive guidance to date on compliance obligations under the beneficial ownership information (BOI) reporting rule. It provides a useful resource in addition to FinCEN's collection of information regarding BOI reporting for companies seeking a better understanding of their obligations under the new rule.

Sep 13, 2023 | mondaq.com | Adam J. Fleisher |Sean Ruff |Obrea Poindexter

Since the beginning of 2023, 12 states – Arkansas, Georgia, Hawaii, Indiana, Iowa, Minnesota, Nevada, New Hampshire, North Dakota, South Dakota, Tennessee and Texas – have passed legislation based, to varying degrees, on the Model Money Transmission Modernization Act (Model Act) developed by the Conference of State Bank Supervisors (CSBS), with input from a working group constituted of industry participants and regulators.

May 9, 2023 | lexology.com | Sean Ruff |Adam J. Fleisher |Obrea Poindexter

After a period of rapid innovation and growth in the virtual currency and digital asset space, state and federal regulators have recently issued statements, guidance and reports that articulate specific concerns and corresponding regulatory expectations with respect to digital asset activities. Case in point is the recent "Illicit Finance Risk Assessment of Decentralized Finance"[1] released by the U.S. Department of the Treasury last month.