The Corporate Transparency Act (“CTA”) became effective on January 1, 2024. When it was first enacted, the law represented a major change in the way many businesses and organizations (both U.S. and non-U.S.) needed to report to the federal government on their structure and beneficial owners. Specifically, the CTA created a national company beneficial ownership registry accessible only by law enforcement, government agencies and other officials, and required reporting companies to provide certain identifying information of its beneficial owners and company applicants to the Financial Crimes Enforcement Network (FinCEN). The CTA’s provisions applied to both newly formed companies and those already established.
More recently, a series of developments in the courts and new rules issued by FinCEN, the agency overseeing implementation of the CTA, injected considerable uncertainty into how companies should navigate the new law. On March 21, 2025, pursuant to President Trump administration’s policy efforts to deregulate and minimize regulatory burdens, FinCEN issued an interim final rule significantly reducing the applicability of the CTA to only non-U.S. companies in limited situations. For more information, refer to this publication.
Important updates to the CTA and its reporting requirements will continue to be to be shared here as they become available.
