Last year in September, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain anti-money laundering and combating the financing of terrorism (AML/CFT) program and other Bank Secrecy Act-related obligations on investment advisers (IA AML Rule) effective January 1, 2026.

In December 2024, Winston’s CTA Task Force attorneys began covering a series of judicial actions that affected the enforcement status of the Corporate Transparency Act and its beneficial ownership information reporting rule.
On December 23, 2023, New York Governor Kathy Hochul signed the LLC Transparency Act into law, with a chapter amendment to be approved by the New York State Legislature. The chapter amendment was later approved, and on March 1, 2024, Governor Hochul signed the amended LLC Transparency Act (the Act) into law. The Act takes effect on January 1, 2026 and requires all limited liability companies formed in New York State or qualified to do business in New York State to file a beneficial ownership disclosure or attestation of exemption with the New York Department of State.