Shedding Light On The Corporate Transparency Act

Corporate Transparency Act ("CTA")

• Enacted by Congress in 2021
• Part of 2021 National Defense Authorization Act
• Intended to assist law enforcement
• • Combat money laundering, fraud, foreign interference, terrorism, and other illegal activities

CTA in a Nutshell

• Requires nearly all small businesses in the US to file reports with FinCEN beginning January 1, 2024
• Reports include information about the company and Beneficial Ownership Information ("BOI") about each of the company's "Beneficial Owners"
• Strict deadlines for initial and updated reports
• Criminal and civil penalties

Statutes and Regulations

• CTA is codified at 31 USC § 5336, et seq.
• Treasury has produced a set of final regulations at 31 CFR 1010.380, et seq.