The CTA requires Reporting Companies to report BOI to FinCEN, and FinCEN will in turn establish a BOI database. The proposed rule outlines circumstances in which authorized recipients can request access to the BOI contained in FinCEN’s database and the data protection protocols and oversight mechanisms that apply. Specifically, the proposed rule provides that FinCEN may only disclose BOI to federal agencies engaged in national security, intelligence, or law enforcement activities; state, local, and Tribal law enforcement agencies that obtain court authorization; U.S. Further, authorized recipients who are given access to BOI must only use the information in furtherance of the activity for which it was disclosed and must implement specific safeguards that protect against unauthorized disclosure.

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List of Internet top-level domains

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Prosecutions for Russian Sanctions and Export Control Violations. As discussed in our prior memorandum, on October 19, 2022, DOJ announced that the U.S. Real Estate Investments by Sanctioned Russian Nationals. On January 25, 2023, FinCEN issued an alert titled “Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies.” The alert focused on the commercial real estate sector as a source of sanctions evasion-related vulnerabilities. FinCEN noted several characteristics of the commercial real estate industry that rendered it particularly vulnerable to exploitation by sanctioned individuals and entities, including, inter alia, highly complex financing methods and opaque ownership structures.

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