The Corporate Transparency Act (“CTA”) was enacted in 2021 as part of the Anti-Money Laundering Act of 2020, requiring certain business entities (“Reporting Companies”) to report beneficial ownership information (“BOI”), and, for entities created or registered on or after January 1, 2024, information with respect to any individual who directly files the document creating the Reporting Company (“Company Applicant”), to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”). McGuireWoods described the CTA’s requirements in a previous post.
On November 7, 2023, FinCEN announced a final rule amending its beneficial ownership information (“BOI”) reporting requirements addressing the circumstances under which Reporting Companies may use an entity’s FinCEN Identifier instead of reporting the BOI of individuals owners of that entity.