When the Corporate Transparency Act took effect earlier this month, most commentary rightly focused on the obligations it imposed and the measures necessary to comply with its terms. As part of that analysis, commentators routinely noted the act contains criminal provisions providing for fines and imprisonment. From a defense perspective, the creation of new crimes
We are less than one year out from the effective date (January 1, 2024) of the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) beneficial ownership information (BOI) reporting rule, and key details about the rule remain unclear. The rule requires most domestic and foreign companies to report their beneficial owners to FinCEN, but the