On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) invited public comment on its proposed rule (the “Proposed Rule”) implementing the beneficial ownership disclosure requirements of the Corporate Transparency Act (“CTA” or “Act”). Comments to the Proposed Rule are
Neal Modi represents individuals and organizations in complex civil disputes and criminal proceedings. Mr. Modi has experience representing companies, financial institutions, and private credit investors in a wide variety of complex, cross-border litigation matters pending before federal district and bankruptcy courts.
Prior to joining the firm, Mr. Modi clerked for Judge Anthony J. Trenga on the United States District Court for the Eastern District of Virginia.
Mr. Modi is a member of the Bar of New York. District of Columbia bar application pending; supervised by principals of the firm.
On Thursday, April 1, 2021, the Financial Crimes Enforcement Network (“FinCEN”) released an advance notice of proposed rulemaking (“ANPR”), presenting the public with its first opportunity to comment on the beneficial ownership disclosure requirements in the Corporate Transparency Act (“CTA”), a key component of the Anti-Money Laundering Act of 2020 (“AMLA”). The ANPR focuses on procedures and standards for beneficial ownership reporting by covered companies, and on the design and use of FinCEN’s planned beneficial ownership database. The ANPR does not address expected modifications to the customer due diligence (“CDD”) requirements of financial institutions, which will be the subject of a separate rulemaking process. Comments on the ANPR are expected to be due on May 5, 2021 — i.e., 30 days after the ANPR is slated for publication in the Federal Register.
This alert summarizes key issues in the ANPR, as relevant both to financial institutions and to reporting companies. …
Continue Reading FinCEN Releases Advance Notice of Proposed Rulemaking on Beneficial Ownership Disclosure Requirements