FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements

On September 30, 2022, the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") published a highly anticipated rule (the "Final UBO Rule" or the "Final Rule") that implements the beneficial ownership information reporting requirements of the Corporate Transparency Act (the "CTA").¹ The CTA, which is part of the Anti-Money Laundering Act of 2020 and enacted into law as a part of the National Defense Authorization Act for Fiscal Year 2021, establishes ultimate beneficial ownership ("UBO") information reporting requirements for the vast majority of privately held corporations, limited liability companies and other similar entities created in, or registered to do business in, any of the states of the United States.