Global Trade & Foreign Policy Insights

On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a rule (the Final Rule) implementing the beneficial ownership information reporting requirements of the Corporate Transparency Act (the CTA).

Financial institutions have long asked how—and to what extent—they need to comply with export controls, and recently, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) have started to respond.

On May 19, 2023, in coordination with the G7 summit in Japan, the U.S. announced new economic sanctions and export controls designed to further restrict the Russian Federation’s (Russia) ability to prosecute its invasion of Ukraine.

On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network published a highly anticipated rule (the “Final UBO Rule” or the “Final Rule”) that implements the beneficial ownership information reporting requirements of the Corporate Transparency Act.

On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM or proposed rule) to implement the beneficial ownership information reporting requirements set forth in Section 6403(a) of the Corporate Transparency Act (CTA), which was enacted as part of the National Defense Authorization Act of Fiscal Year 2021 (NDAA).

This year has brought several important sweeping regulatory changes in the United States, including the most substantive Bank Secrecy Act (BSA)/anti-money laundering (AML) reform since the U.S. PATRIOT ACT of 2001.

On December 11, 2020, as part of the National Defense Authorization Act for Fiscal Year 2021 (NDAA), the U.S. Senate passed the Corporate Transparency Act (CTA). As we reported earlier this year, the House of Representatives passed its version of the Corporate Transparency Act in October 2019, and it was later included in the NDAA.