The Corporate Transparency Act: 2025 Update

Jonathan N. Halpern
Alan Winston Granwell
Michael C. Titens
Kara Koerner
Jonathan N. Halpern | Holland & Knight
Alan Winston Granwell | Holland & Knight
Michael C. Titens | Holland & Knight
Kara Koerner | Holland & Knight
On-Demand: January 31, 2025

2 hour CLE

Tuition: $195.00
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Program Summary

Stay ahead of the latest developments in compliance with this in-depth program on the Corporate Transparency Act (CTA). This program explores the CTA's implementation under the Anti-Money Laundering Act (AMLA) and its critical role in combating financial secrecy and illegal financial activities. Learn about reporting company definitions, beneficial ownership requirements, and the complexities of initial and ongoing reporting obligations. Gain valuable insights into compliance strategies, risk mitigation, and the secure handling of Beneficial Ownership Information Reports (BOIR). With a forward-looking analysis of FinCEN guidance and potential amendments, this update equips attorneys and their clients with the tools to navigate the CTA effectively in 2025 and beyond.

Key topics to be discussed:

  • Background and Rationale
  • Scope of Applicability
  • Beneficial Owners and Company Applicants: Definitions and Challenges
  • Initial and Ongoing Reporting Requirements
  • Compliance Strategies for Attorneys and Their Clients
  • Penalties and Enforcement Risks
  • Access, Privacy, and Security of BOIR Data
  • Key Takeaways and Best Practices
  • Next Steps: What to Expect

Closed-captioning available

Speakers

Jonathan N. Halpern_myLawCLEJonathan N. Halpern | Holland & Knight

Jonathan N. Halpern is a seasoned litigator who draws on his extensive experience in a wide array of white collar criminal defense matters, and as a former federal prosecutor in the Southern District of New York (SDNY), to represent corporations and individuals in investigations and prosecutions spanning a breadth of criminal issues. He has litigated complex criminal and civil matters, but a substantial portion of his defense practice entails engaging with prosecutors and regulatory lawyers to resolve federal and state criminal and agency investigations for his clients away from the public spotlight. A legal strategist and problem solver, Mr. Halpern is a skillful and relentless negotiator and advocate both in court and behind the scenes, where he has quietly achieved client success in securing the dismissal of federal criminal felonies. Prosecutors, clients and adversaries have credited him for his creativity in proposing resolutions to challenging issues.

Mr. Halpern represents corporate and individual clients in internal and government investigations in a wide array of criminal, cross-border and compliance issues. Business and educational institutions and individuals turn to Mr. Halpern to represent them in a broad array of matters encompassing financial services; cybersecurity; Foreign Corrupt Practices Act (FCPA); false claims and other healthcare matters; securities, commodities, and tax, among other issues. He also handles representation and defense in investigations and litigation involving allegations of sexual assault, harassment and workplace misconduct. Mr. Halpern represents clients in federal and state court, as well as in matters involving U.S. Attorney’s Offices, New York State Attorney General’s Office, New York County District Attorney’s Office, U.S. Department of Justice (DOJ), U.S. Department of the Treasury, U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC). His clients span diverse industries from cybersecurity, banking, investor funds, mortgage and other financial services to pharmaceutical and healthcare, media, energy services, manufacturing and retail.

In addition, Mr. Halpern is experienced in representations involving allegations of wrongdoing in the workplace and has successfully defended executives in investigations and litigation alleging sexual assault, harassment and other misconduct.

Mr. Halpern handles substantial pro bono legal work, including immigration asylum cases, and he has successfully secured asylum for individuals seeking to escape persecution in their homelands. One escapee, who was arrested at the U.S. border and detained for approximately nine months, was granted asylum – and his freedom – after Mr. Halpern litigated his case and prevailed at trial. Mr. Halpern agreed to take the case after several lawyers had declined to do so. More recently, he succeeded in securing asylum for the client’s spouse and children, assisting them to be reunited after years apart. After extensive work by Mr. Halpern and a firm associate, another pro bono client recently was granted asylum for fear of being persecuted in a former Soviet republic because of his sexual orientation. For his commitment and achievements, Mr. Halpern was named a Holland & Knight Public & Charitable Service All Star in 2019 and has consistently been named a Pro Bono All Star.

Mr. Halpern’s tenure as a federal prosecutor in the SDNY included service as chief of the Major Crimes Unit. In that position, he supervised approximately 25 experienced federal prosecutors in investigations and prosecutions of international bribery, money laundering, healthcare and tax fraud, computer crimes, Bank Secrecy Act violations and other complex, large-scale financial crimes. As a federal prosecutor, Mr. Halpern investigated and prosecuted white collar crimes involving public corruption, extortion, money laundering, federal tax violations, bank fraud and wire, mail and healthcare fraud. He served as lead prosecutor in several high-profile matters, including the investigation of the presidential pardon of Marc Rich, and supervised the investigation of corruption allegations in the United Nation’s Oil for Food Program.

 

Alan Winston Granwell_myLawCLEAlan Winston Granwell | Holland & Knight

Alan Granwell is an attorney in Holland & Knight’s Washington, D.C., office, with more than 50 years of experience in international taxation. In his long and wide-ranging career, he has represented multinational corporations and globally oriented high-net-worth clients in a broad array of international tax planning, compliance and controversy matters, including serving as an expert witness.

Mr. Granwell also advises on tax transparency initiatives, including the Corporate Transparency Act (which will have widespread application to privately held companies and their beneficial owners), the Foreign Account Tax Compliance Act, the Common Reporting Standard and the U.S. Department of Justice Swiss Bank Program.

In the early 1980s, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of the Treasury. In that capacity, Mr. Granwell was the senior international tax adviser at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulatory and administrative matters involving international taxation and directing the U.S. tax treaty program.

Mr. Granwell began his career working at Wall Street law firms. He then moved to Washington, D.C., to accept his government appointment to work for the Treasury Department. Thereafter, he returned to private practice in Washington, D.C. Prior to joining Holland & Knight, Mr. Granwell was a tax attorney for a boutique international tax law firm.

Mr. Granwell is a Fellow of the American College of Tax Counsel and a well-known, frequent commentator and lecturer on international tax matters. He has authored numerous articles for publications, both in the United States and abroad. He has made presentations for the American Bar Association, Section of Taxation, the International Bar Association, the International Fiscal Association, the Society of Trust and Estate Practitioners (STEP) and other organizations in numerous countries around the world. Mr. Granwell also is an active member of the STEP, particularly organizing, moderating and presenting at educational webinars, and is a former chair of the Mid Atlantic Branch, the current Co-Director of Programs for the Mid Atlantic Branch, and a frequent contributor to STEP USA Alerts.

 

Michael C. Titens_myLawCLEMichael C. Titens | Holland & Knight

Michael Titens is a corporate attorney in Holland & Knight’s Dallas office.

Mr. Titens represents U.S. and international clients in structuring, negotiating and implementing mergers and acquisitions (M&A) as well as joint ventures. He also represents private equity funds and portfolio companies in formation, financing and M&A transactions.

Mr. Titens frequently represents Mexican and other international clients in M&A, foreign investment and other business transactions. He was a resident in the firm’s Monterrey, Mexico, office from 1993 to 1997.

Mr. Titens also focuses on cybersecurity issues, including breach preparedness and responses, and previously served as co-chair of the firm’s Cybersecurity and Data Privacy Group.

 

Kara Koerner_myLawCLEKara Koerner | Holland & Knight

Kara Koerner is a private wealth services attorney in Holland & Knight’s Century City office. Ms. Koerner advises individuals and families on complex matters, including international and domestic wealth and asset transfers, pre-immigration and expatriation planning, international corporate tax matters, structuring and reorganizing multinational businesses to minimize worldwide taxes and foreign investment matters in the United States.

Ms. Koerner’s skills include handling complex matters involving the global art market, and navigating California property tax reassessment issues arising in business succession matters.

Ms. Koerner uses decades of personal and professional experience to design and implement tax-efficient strategies for cross-border individuals and families, as well as corporations with a global footprint. Her practice focuses on helping clients with matters inherent to living and transacting business globally, including international and domestic wealth and asset transfers. As a former U.N. attorney, Ms. Koerner is fluent in French and has worked across the cultures of more than 100 countries.

Prior to joining Holland & Knight, Ms. Koerner served as counsel at a boutique private wealth services law firm in Los Angeles. Previously, Ms. Koerner designed gift and business succession planning strategies for international families, including the transfer of ownership interests of real estate in California.

She also represented entrepreneurs in mergers and acquisitions (M&A) transactions, real estate developers in negotiating commercial loan and development agreements, art collectors in litigation regarding fraudulent transactions and the United Nations Educational, Scientific and Cultural Organization (UNESCO) in Paris regarding treaties aimed at protecting art from illicit trafficking and armed conflict.

Agenda

I. Background and Rationale | 1:00pm – 1:10pm

  • CTA’s enactment under the Anti-Money Laundering Act (AMLA)
  • The U.S. role in combating financial secrecy and the rise of the CTA
  • Key objectives: Curbing shell companies, money laundering, and illegal financial activities

II. Scope of Applicability | 1:10pm – 1:20pm

  • Definition of “reporting companies”
  • Differences between domestic and foreign reporting companies

III. Beneficial Owners and Company Applicants: Definitions and Challenges | 1:20pm – 1:30pm

  • What qualifies as a “beneficial owner” (substantial control, ownership thresholds)
  • Definition of “company applicant” and reporting requirements
  • Challenges in identifying “substantial control” and navigating ambiguous categories

IV. Initial and Ongoing Reporting Requirements | 1:30pm – 1:40pm

  • Filing deadlines based on the date of company creation/registration
  • Requirements for the Beneficial Ownership Information Report (BOIR)
  • Role of the FinCEN Identifier (FinCEN ID) in simplifying compliance

V. Compliance Strategies for Attorneys and Their Clients | 1:40pm – 1:50pm

  • Helping clients determine if they qualify as a reporting company
  • Advising on exemptions and eligibility criteria
  • Navigating BOIR submissions: Accuracy, updates, and timelines

VI. Penalties and Enforcement Risks | 1:50pm – 2:00pm

  • Civil and criminal penalties for non-compliance
  • Risk mitigation strategies for businesses

Break | 2:00pm – 2:10pm

VII. Access, Privacy, and Security of BOIR Data | 2:10pm – 2:30pm

  • FinCEN’s secure database and limitations on public access
  • Ensuring clients’ sensitive information remains protected

VIII. Key Takeaways and Best Practices | 2:30pm – 2:50pm

  • Actionable steps for ensuring compliance under the CTA
  • Future considerations: Evolving FinCEN guidance and potential amendments

IX. Next Steps: What to Expect | 2:50pm – 3:10pm

Credits

Alaska

Approved for CLE Credits
2 General

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Alabama

Approved for Self-Study Credits
2 General

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Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hours

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2.5 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Approved for CLE Credits
2 General

Hawaii

Approved for CLE Credits
2.4 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Pending CLE Approval
2 General

Indiana

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hours

Maryland

No MCLE Required
2 CLE Hours

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hours

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for Self-Study Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General Minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Pending CLE Approval
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for Self-Study Credits
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hours

Tennessee

Approved for Self-Study Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal Hours

Receive CLE credit in Washington via Attorney Submission. myLawCLE will supply Washington state attorneys with instructions on how to gain credit.
Wisconsin

Approved for Self-Study Credits
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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