Compliance Stuff

Key takeaways: The details for the New York LLC Transparency Act (NY LLCTA) are still under review and subject to change. Stakeholders should stay informed about updates as they become available. LLCs operating in New York will need to comply with the NY LLCTA starting Jan 1, 2026 . The NY LLCTA requires LLCs to annually disclose detailed information about their beneficial owners to the New York Department of State. LLCs should begin compiling their ownership information so they are prepared to file before the deadline. b What Is the New York LLC Transparency Act? Beginning January 1, 2026, the New York LLC Transparency Act (NY LLCTA) will require most limited liability companies (LLCs) that are either formed in New York or authorized to do business there to report information about their beneficial owners to the New York Department of State (NYDOS) . Modeled after the federal Corporate Transparency Act (CTA), this law is intended to enhance...

  In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports. The Corporate Transparency Act (CTA) plays a vital role in protecting the U.S. and international financial systems, as well as people across the country, from illicit finance threats like terrorist financing, drug trafficking, and money laundering. The CTA levels the playing field for tens of millions of law-abiding small businesses across the United States and makes it harder for bad actors to exploit loopholes in order to gain an unfair advantage. On Tuesday, December 3, 2024, in the case of  Texas Top Cop Shop, Inc., et al. v. Garland, et al. , No. 4:24-cv-00478 (E.D. Tex.), the U.S. District Court for the Eastern District of Texas, She...

  In light of a December 23, 2024, federal Court of Appeals decision,  reporting companies, except as indicated below, are once again required to file beneficial ownership information with FinCEN . However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, we have extended the reporting deadline as follows: Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.) Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. Reporting companie...

FinCEN has learned of fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act (CTA). Scammers are on the hunt to steal sensitive and private information from individuals and entities who may be subject to reporting requirements under the CTA. The scams under the CTA fraud alert are letters and emails that impersonate IRS tax documents by using the fraudulent title of “Important Compliance Notice” and request the recipient of the correspondence to click a link or scan a QR code. The CTA Fraud Alert from FinCEN highlights fraudulent scams that may include: Correspondence requesting payment. There is NO fee to file BOI (Beneficial Ownership Information) directly with FinCEN. FinCEN does NOT send correspondence requesting payment to file BOI. Do not send money in response to any mailing that claims to be from FinCEN or another government agency. Correspondence that asks the recipient to click...