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CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged

By Marina Olman-Pal, Donald S. Lee & Tiffanie Monplaisir on January 12, 2026
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The U.S. Court of Appeals for the Eleventh Circuit in National Small Business United vs. U.S. Department of the Treasury reversed the decision of the U.S. District Court for the Northern District of Alabama decision, which found that the Corporate Transparency Act (CTA) is constitutional.

Link to Click here to read the full GT Alert. Click here to read 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 Donald S. Lee Donald S. Lee

Donald S. Lee serves as Greenberg Traurig’s Assistant General Counsel and Director of Firm Services. Don advises the firm in the areas of technology policy, data protection, technical forensics, contract administration, IP docketing, Litigation docketing and risk management. Don is also responsible for…

Donald S. Lee serves as Greenberg Traurig’s Assistant General Counsel and Director of Firm Services. Don advises the firm in the areas of technology policy, data protection, technical forensics, contract administration, IP docketing, Litigation docketing and risk management. Don is also responsible for the firm-wide management of all electronic and paper records including litigation holds, data preservations and ethical walls.

Prior to joining Greenberg Traurig, Don worked as a Senior Staff Attorney in the areas of Antitrust and Commercial Litigation, as well as on Capitol Hill with the Senate Judiciary Committee in the Antitrust, Monopolies and Business Rights Sub-Committee and the Department of Justice, Civil Division, Voting Litigation Section.

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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:
    Business and Commercial
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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