In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”
Continue Reading Federal and State Efforts Intensify Focus on ‘Debanking’
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
Continue Reading CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged
On Sep. 8, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it issued a new Geographic Targeting Order (September GTO) that renewed and modified FinCEN’s GTO announced on March 11, 2025 (March GTO).
Continue Reading Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO
On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing that it will extend the effective date of the final rule establishing anti-money laundering/countering the financing of terrorism program and suspicious activity report filing requirements for certain investment advisers and exempt reporting advisers (IA AML Rule), from Jan. 1, 2026, to Jan. 1, 2028.
On July 18, 2025, President Trump enacted the GENIUS Act, the first comprehensive crypto legislation in U.S. history. The law introduces rigorous rules for payment stablecoins, including mandatory federal or state approval, 1:1 reserve backing, and enhanced disclosure obligations. Digital asset service providers must fully comply by July 2028.
On March 21, 2025, FinCEN issued an interim final rule narrowing the scope of the CTA’s BOI Reporting Rule (Reporting Rule) to foreign reporting companies and foreign beneficial owners.
On Jan. 23, 2025, the U.S. Supreme Court granted the U.S. government’s request for a stay (SCOTUS Order) of the nationwide preliminary injunction of the Corporate Transparency Act (CTA) issued
Continue Reading CTA UPDATE: Enforcement Remains Suspended Despite U.S. Supreme Court Granting Stay of Preliminary Injunction
Federal and state “fair access” or “anti-debanking” laws and regulations have been evolving quickly over the last five years, closely tracking the changing U.S. political climate. These laws and regulations
Continue Reading US Fair Access and Anti-Debanking Laws: What to Expect Under the New Administration
On Dec. 26, 2024, the nationwide preliminary injunction that a Texas district court issued in Texas Top Cop Shop, Inc. v. Garland against enforcement of the Corporate Transparency Act (CTA)
Continue Reading CTA Update: Nationwide Preliminary Injunction Against CTA Reinstated
The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United
Continue Reading CTA Countdown: Upcoming FinCEN Filing Deadlines