Corporate Transparency Act Resource Page

Liskow will post updates about the Corporate Transparency Act on this resource page.

Background

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule on September 29, 2022, implementing the beneficial ownership information reporting requirement of the Corporate Transparency Act (CTA), which was passed by Congress as part of the Anti-Money Laundering Act of 2020. In a nutshell, the final rule requires certain domestic and foreign entities to submit specified beneficial ownership to FinCEN.

Top Things Businesses Should Know About the Corporate Transparency Act

1. Most businesses will be required to report to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department identifying information about the business and its owners.
2. For most businesses, Beneficial Ownership Information (“BOI”) reports will now be due by March 21, 2025 according to a FinCEN Notice updating deadlines for filing BOI reports. Any businesses which had previously received an extended deadline beyond March 21, 2025, such as for disaster relief, will retain the later filing deadline.
3. Reporting will be done electronically through a secure filing system, and beneficial ownership information will be stored in a nonpublic database.
4. Penalties for noncompliance can be severe.
5. Congress is also considering legislation to extend the deadline until next year.
6. Businesses should consult with their legal counsel to help navigate the rules and exemptions relating to the CTA.

Corporate Transparency Act Resources

• Recent Liskow Updates
• The Treasury Department’s Frequently Asked Questions Resource Page
• The Financial Crimes Enforcement Network of the Treasury Department Resource Page

Questions?

Should you have questions about this new rule or about general Corporate Transparency Act matters, feel free to reach out to Leon Rittenberg III, Julie Chauvin or Marilyn Maloney.