July 11, 2026
The Final Rule, published by the Financial Crimes Enforcement Network (“FinCEN”) on September 30, 2022, was challenged just six weeks later when Plaintiffs Isaac Winkles and the National Small Business Association (“NSBA”) filed suit in the United States District Court for the Northern District of Alabama alleging that Congress lacked authority under the Constitution to enact the CTA’s mandatory disclosure requirements.
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