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Jan 6, 2025 | 
mondaq.com | Robert Johnston |Melissa Wiley |Paula Ladd |Samantha Sigelakis-Minski
In a surprise ruling, yesterday the Fifth Circuit Court ofAppeals vacated its own stay of the Eastern District of Texas'Dec. 3 nationwide preliminary injunction enjoining enforcement ofthe Corporate Transparency Act (CTA).1 On Dec. 23, thatDec.
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Sep 26, 2024 | 
mondaq.com | Robert Johnston |Melissa Wiley |Paula Ladd |Ryan Fennell
On September 20, the District Court for the District of Oregon denied a motion for a preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA) on the basis that the plaintiffs' claim that the CTA was unconstitutional was not likely to prevail.1 This is the first federal court to have addressed the issue of the CTA's constitutionality since the District Court for the Northern District of Alabama held earlier this year that the CTA exceeded Congress' authority and...
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Sep 3, 2024 | 
mondaq.com | Scott Moss |Paula Ladd |Samantha Sigelakis-Minski |Robert Johnston
On August 28, the United States Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule (the "Final Rule") subjecting certain registered investment advisers (RIAs) and exempt reporting advisers registered with the Securities and Exchange Commission (SEC) (ERAs; collectively with RIAs, Investment Advisers)1 to the anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements of the Bank Secrecy Act and its amendments (BSA).2...
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Jun 19, 2024 | 
anti-corruption.com | Robert Johnston
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May 29, 2024 | 
mondaq.com | Melissa Wiley |Robert Johnston |Ryan Fennell
On May 23, 2024, the California Senate passed a bill that, if
approved by the California Assembly before August 31, 2024, and
signed into law by Gov.
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Apr 10, 2024 | 
law360.com | Robert Johnston |Gary Feldon
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Apr 10, 2024 | 
law360.co.uk | Robert Johnston |Gary Feldon
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Feb 23, 2024 | 
mondaq.com | Robert Johnston |Paula Ladd |Ryan Fennell |Samantha Sigelakis-Minski
The United States Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting advisers (ERAs; collectively with RIAs, Investment Advisers)1 to the anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements of the Bank Secrecy Act (BSA).2 As discussed in our prior Client Alert,3 FinCEN previously advised that an NPRM...
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Feb 1, 2024 | 
mondaq.com | Robert Johnston |Paula Ladd |Jimmy Kang |Samantha Sigelakis-Minski
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The United States Department of the Treasury (U.S. Treasury)
announced that it aims to publish a proposed rule in early 2024
(the 2024 NPRM) that would subject investment advisers to the
anti-money laundering (AML) requirements of the Bank Secrecy Act
(BSA).1
This is not the first time that lawmakers have attempted to
bring investment advisers into the ambit of the BSA.
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Jan 21, 2024 | 
mondaq.com | Robert Johnston |Melissa Wiley |Paula Ladd |Samantha Sigelakis-Minski
On Dec. 22, New York Governor Kathy Hochul signed the New York
Limited Liability Company Transparency Act (NY LLC Transparency
Act) into law.1 The NY LLC Transparency Act is modeled
on the Corporate Transparency Act (CTA), a federal law aimed at
tackling tax evasion and financial crimes, that took effect Jan. 1.2 We discussed how companies can prepare for the CTA
in a prior Client Alert and explained the CTA Final Rule
and its requirements in a subsequent Client Alert.
