Archive

On Friday March 21st, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. In the interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or […]

As you’re probably already aware, FinCEN issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) on December 22, 2023. This rule implements portions of the Corporate Transparency Act (CTA) and authorizes certain persons access to information reported to FinCEN regarding reporting companies, beneficial owners, and company applicants (BOI). On February 20, 2024, the effective date of the Access Rule, FinCEN published a Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards […]

Yesterday, FinCEN announced a filing deadline extension for Beneficial Ownership Information for companies created or registered in 2024. Beginning January 1, 2024, reporting companies will be required to file information with FinCEN regarding their beneficial ownership. The rule requires new reporting companies, that is those created after January 1, 2024, to file their initial report within 30 calendar days of “receiving actual or public notice that the creation or registration of the reporting company is […]

Earlier this week on November 7, 2023, FinCEN issued a Final Rule on the use of FinCEN identifiers in Beneficial Ownership information reporting after commenters raised concerns that the previously proposed language could actually obscure the identities of beneficial owners. The Final Rule provides clear criteria on the use and reporting of an entity’s FinCEN identifier. What is a FinCEN identifier? A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an […]

On December 8, 2021, the Financial Crimes Enforcement Network (FinCEN) proposed regulations to require certain entities to file reports with FinCEN that identify two categories of individuals: The beneficial owners of the entity; and Individuals who have filed an application with specified governmental authorities to form the entity or register it to do business. The proposed regulations would implement Section 6403 of the Corporate Transparency Act (CTA), enacted into law as part of the National […]