Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations
Overview June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on January 1, 2024. During this period, millions of newly formed companies have already filed their beneficial ownership information reports (BOIRs) with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). But tens of millions more companies that were created or registered to do business before January 1, 2024, will be required to file their initial reports by January 1, 2025 . With five months left to evaluate the complex legal issues surrounding application of and reporting under the CTA, as well as gather relevant beneficial ownership information, these existing entities s hould be taking steps now to prepare to file their reports by the deadline. Since the enactment of the CTA and the launch of the Beneficial Ownership Sec...