Skip to main content

CTA Task Force

On Jan. 1, 2024, the Corporate Transparency Act (CTA) took effect, requiring non-exempt U.S. entities and non-exempt foreign entities registered to do business in the United States to submit beneficial ownership information (BOI) reports to a confidential database maintained by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

The CTA and its implementing regulations mandate that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) report certain BOI to FinCEN. According to FinCEN, this reporting requirement is intended to enhance the ability of FinCEN and other agencies to protect the U.S. financial system from illicit use, bringing the United States in line with at least 30 other countries that have implemented some form of central register of BOI.

The CTA represents a groundbreaking shift in how the federal government monitors beneficial ownership of U.S. Reporting Companies. With an estimated 32.6 million companies expected to comply with the CTA, companies must be aware of the CTA’s broad applicability to entities within their structures. To prepare for compliance, reporting companies should familiarize themselves with the CTA’s requirements and establish internal processes for identifying and updating information on beneficial owners, including boards of directors, foreign affiliates, senior officers, and those controlling a company.

GT monitors developments involving the CTA on an ongoing basis (including recent challenges), as well as legislation by individual states to enact similar disclosure requirements.

Helpful Links:

Beneficial Ownership Information Reporting | FinCEN.gov

Beneficial Ownership Information | FinCEN.gov

BOI Informational Brochure (fincen.gov)

GT Links:

FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements | Insights  | Greenberg Traurig LLP (gtlaw.com)

FinCEN Updates Frequently Asked Questions on Beneficial Ownership Reporting Rule Ahead of Jan. 1, 2024, Effective Date | Insights | Greenberg Traurig LLP (gtlaw.com)

Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements | Insights | Greenberg Traurig LLP (gtlaw.com)

FinCEN Publishes Final Rule on Access to Beneficial Ownership Information | Insights | Greenberg Traurig LLP (gtlaw.com)

District Court Declares Corporate Transparency Act Unconstitutional | Insights | Greenberg Traurig LLP (gtlaw.com)

NY Gov Signs Amended LLC Transparency Act | Insights | Greenberg Traurig LLP (gtlaw.com)

California Senate Passes State's Version of Corporate Transparency Act | Insights | Greenberg Traurig LLP (gtlaw.com)