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Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements

By Marina Olman-Pal, Robert Mangas & Tiffanie Monplaisir on October 6, 2023
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The Corporate Transparency Act of 2019 (CTA), enacted as part of the Anti-Money Laundering Act of 2020, requires, for the first time, that certain U.S. legal entities and foreign entities registered to do business in the United States disclose information regarding their beneficial owners and persons who register or form them to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). On Sept. 29, 2022, FinCEN published a final rule (Final Rule) implementing the beneficial ownership information (BOI) reporting provisions of the CTA.[1] Now one year later, FinCEN has published proposed rules and guidance to implement the BOI reporting requirements of the CTA, as described below.

Continue reading the full GT Alert.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Robert Mangas Robert Mangas

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in multiple policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial services, information…

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in multiple policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial services, information technology, artificial intelligence, manufacturing, tax, education, pensions, defense, and foreign relations. Rob has a depth of understanding of the rules of the U.S. Senate and House of Representatives, and he has deep experience in legislative drafting. He previously served as chief of staff to U.S. Senator Wendell Ford, the former Senate Majority Whip.

Rob is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that draws on the firm’s global platform to guide our clients through what comes next in regards to tariffs, including tariff refund matters, tax, litigation, and M&A activity spurred by these global shifts.

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal

…

Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

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  • Posted in:
    Other
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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