Member Articles

Milton Springut and Barry Werbin, attorneys in Herrick's Intellectual Property and Technology Group, authored an article for the New York Law Journal discussing two recent decisions made by the Court of Appeals for the S ...

New FinCEN Guidance. In new regulatory guidance issued on March 21, 2025 (the "Interim Final Rule"), the U.S. Department of Treasury (FinCEN) limits the Corporate Transparency Act ("CTA") solely to foreign entities previ ...

n a press release dated March 2, 2025, the U.S. Department of Treasury ("Treasury") announced it will eventually restrict the CTA's scope to "foreign reporting companies only." With this ultimate goal in mind, Treasury w ...

Q: When is a deadline not really a deadline?A: When there is no penalty for missing the deadline. On February 27, 2025, FinCEN announced that it will not issue "any fines or take any other enforcement actions against an ...

TL;DR: The Corporate Transparency Act (CTA) is back in effect with March 21 deadline. What just happened? In an order signed on February 17, 2024, the District Court in Smith v U.S. Department of the Treasury struck dow ...

Despite recent developments at the U.S. Supreme Court (discussed below), enforcement of the Corporate Transparency Act ("CTA") remains suspended nationwide - at least for the moment. A Tale of Two Injunctions. In the la ...