FinCEN Simplifies CDD Requirements for Financial Institutions

On February 13, 2026, FinCEN issued an Order providing “exceptive relief” to covered financial institutions (including banks, savings associations, and broker-dealers). The order simplifies the requirements for obtaining beneficial ownership information (“BOI”) for a legal entity customer each time the customer opens a new account. Under the Order, a covered financial institution is required to …

CTA – Where Does It Stand Today?

The Corporate Transparency Act (the “CTA” or the “Act”) has dropped off of most people’s radar, perhaps prematurely.  Although December 2025 was not the CTA roller coaster that December 2024 was,[1] it still provided some year-end entertainment. You may remember that the Financial Crimes Enforcement Network, an arm of the U.S. Department of the Treasury (“FinCEN”), …