Awareness of New Corporate Transparency Act

We want to make you aware of a law, the Corporate Transparency Act (CTA), which was enacted in 2021 to combat money laundering, tax fraud, and other illicit activities through business entities. Beginning in January 2024, the CTA requires certain business entities (i.e., reporting companies) to file beneficial ownership information (BOI) with the Financial Crimes Enforcement Network (FinCEN).

If you operate your business using a separate legal entity—such as a corporation, LLC, or entity created or formed by a filing with your state—you will likely need to report under the CTA. There are exemptions for certain types of entities, however. Information regarding these exemptions and the BOI reporting requirements can be found at

If an entity is required to report, it must provide the following information through FinCEN’s Beneficial Ownership Secure System (BOSS) for each beneficial owner:

  • Full legal name
  • Date of birth
  • Current residential or business street address
  • One of the owner’s/applicant’s passport number, driver’s license number, FinCEN identifier, or other government-issued identification document number

The CTA also requires updates for material changes in beneficial ownership and imposes penalties for noncompliance.

If My Entity Needs to File, When Is the Deadline to File?

  • For entities in existence before January 1, 2024, reports are due by January 1, 2025.
  • For entities created on or after January 1, 2024, the initial report must be filed within 90 days of receiving actual or public notice that the creation or registration of the reporting company is effective.

The owner(s) of the entities subject to CTA reporting shall have sole responsibility for compliance with this new law, and failure to do so by the reporting deadline may result in fines.

Please consider consulting with legal counsel if you have questions regarding the applicability of the CTA’s reporting requirements and issues surrounding the collection of relevant ownership information.

If you have further questions on this or anything else, please contact us at your earliest convenience.

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