As 2024 comes to a close, companies created prior to January 1,
2024 should be mindful of the year-end deadline to analyze whether
they must report Beneficial Ownership Information ("BOI")
to the U.S. Department of Treasury's Financial Crimes
Enforcement Network ("FinCEN") pursuant to the reporting
provisions of the Corporate Transparency Act ("CTA").
Companies should take immediate action to determine whether filing
is necessary to avoid potential civil and/or criminal penalties.
McGuireWoods described the CTA's requirements in a previous
post and the requirements are also summarized below.
Reporting Requirements
The CTA requires certain domestic and foreign corporations,
LLCs, or other entities to report BOI to FinCEN for all Beneficial
Owners. Beneficial Owners are those that own, directly or
indirectly, 25% of the Reporting Company, or individuals who
exercise substantial control. Substantial control means:
