Corporate Transparency Act Update—FinCEN Issues Final Rule

On September 29, 2022, the Financial Crimes Enforcement Network ("FinCEN") issued the highly anticipated final rule, Beneficial Ownership Information Reporting Requirements (the "Final Rule"), implementing the beneficial ownership disclosure requirements of the Corporate Transparency Act (the "CTA"). The CTA drastically expands current beneficial ownership reporting obligations in order to combat the illicit use of shell companies and to shift the burden of identifying beneficial owners of such companies from financial institutions to the government itself.

Under the Final Rule, certain entities will be required to disclose identifying and beneficial ownership information to the U.S. federal government. The Final Rule will take effect on January 1, 2024 and offers a one-year grace period for entities created or registered prior to the effective date. Reporting companies created or registered on or after January 1, 2024 will have 30 days to file their initial