The Corporate Transparency Act
The Corporate Transparency Act (“CTA”) became effective on January 1, 2024. The landmark law represents a major change in the way many businesses and organizations (both U.S. and non-U.S.) need to report to the federal government on their structure and beneficial owners. Specifically, the CTA creates a national company beneficial ownership registry accessible only by law enforcement, government agencies and other officials, and requires reporting companies to provide certain identifying information of its beneficial owners and company applicants to the Financial Crimes Enforcement Network. Notably, the CTA’s provisions apply to both newly formed companies and, after a phase-in period, those already established.
Reporting companies created or registered on or after January 1, 2024 and before January 1, 2025 have 90 days to file their initial Beneficial Ownership Information (“BOI”) report, and reporting companies created or registered on or after January 1, 2025 have 30 days to file their initial BOI report. Reporting companies in existence prior to January 1, 2024 have until January 1, 2025 to file their initial BOI report. Given the stiff penalties involved with non-compliance, it is critical for affected companies and organizations to prioritize adequate preparation. The resources presented here provide overviews of the CTA’s requirements, best practices for compliance, and updates on the law’s implementation.
APRIL 2022 - The Financial Crimes Enforcement Network (FinCEN) announced the renewal and expansion of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.