Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 30 July 2025 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, published a civil monetary penalty of £300,000 against Markom Management Limited (MML UK), a London-incorporated provider of corporate-services and management functions to its parent Markom Management Cyprus. The penalty (decision dated 10 January 2025) relates to MML UK instructing the transfer of £416,590.92 from a Moscow-based bank account of its parent's client to a person designated under an EU Regulation 269/2014 asset freeze (Russia/Crimea-related), at a time when MML UK had knowledge of the recipient's designated status. OFSI initially proposed £400,000; MML's representations secured a reduction to £300,000, which was subsequently upheld on ministerial review under s.147 of the Policing and Crime Act 2017. At the time of publication this was the third-largest OFSI civil monetary penalty imposed since the powers were introduced under Part 8 of the Policing and Crime Act 2017, and the twelfth use of those powers in total.

FinCEN issued an interim final rule (FR Doc 2025-05199, 90 FR 13688, published March 26, 2025) revising the definition of "reporting company" under the Corporate Transparency Act to mean only entities formed under the law of a foreign country that have registered to do business in a U.S. State or tribal jurisdiction. All entities created in the United States — previously known as "domestic reporting companies" — and U.S. persons are exempted from BOI reporting. Foreign reporting companies registered before March 26, 2025 must file by April 25, 2025; those registered on or after that date have 30 days from registration. Foreign reporting companies are not required to report any U.S. persons as beneficial owners. The IFR is effective immediately; FinCEN is accepting comments and intends to finalize the rule.

FinCEN published the Beneficial Ownership Information Access and Safeguards Final Rule (FR Doc 2023-27973, 88 FR 88732, December 22, 2023; effective February 20, 2024), implementing the access and disclosure provisions of Section 6403(c) of the Corporate Transparency Act (CTA) enacted as part of the Anti-Money Laundering Act of 2020. The rule defines six categories of authorized recipients permitted to access the FinCEN BOI database — US federal agencies engaged in national security/intelligence/law enforcement, state/local/tribal law enforcement, foreign law enforcement and competent authorities (via intermediary federal agency), financial institutions using BOI for customer due diligence (CDD), federal functional regulators assessing financial-institution CDD compliance, and Treasury officers/employees. Access is to be phased in, beginning with a 2024 pilot for key federal agencies before extending to financial institutions and their supervisors. The rule establishes data-security standards, re-disclosure prohibitions, and oversight mechanisms governing each recipient category.

FinCEN published a final rule (FR Doc 2023-26399, 88 FR 83499, November 30, 2023; effective January 1, 2024) extending the initial beneficial ownership information (BOI) reporting deadline under the Corporate Transparency Act (CTA) for reporting companies created or registered in calendar year 2024. Rather than the default 30-day window, these companies receive 90 calendar days from the date of receiving actual or public notice of creation or registration becoming effective to file their initial BOI reports with FinCEN. Companies created before January 1, 2024 retain their original deadline of January 1, 2025; companies created on or after January 1, 2025 revert to the standard 30-day window.

FinCEN published a final rule (FR Doc 2023-24559, 88 FR 76995, November 8, 2023; effective January 1, 2024) specifying when and how entities required to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA) may use another entity's FinCEN identifier in lieu of disclosing the underlying individual beneficial owners. A reporting company may substitute a related entity's FinCEN ID when: (1) that entity has obtained a FinCEN identifier and provided it to the reporting company, (2) the individual is a beneficial owner solely through an ownership interest in the other entity, and (3) the beneficial owners of both entities are the same. Any change to beneficial ownership of the other entity requires an updated BOI report, after which the entity FinCEN identifier may no longer be used until recertified.