Reporting Beneficial Owners Under the Corporate Transparency Act
On January 1, 2024, the Corporate Transparency Act (“CTA”) comes into effect. This sweeping new law imposes significant reporting obligations upon entities that are required to report beneficial ownership and registrant information to the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”). On September 29, 2022, FinCEN adopted its long-awaited final rule (the “Final Rule”) to […]

Robert Appleton and Jason Saltsberg are Partners and Brian Roe is an Associate at Olshan Frome Wolosky LLP. This post is based on their Olshan memorandum.
On January 1, 2024, the Corporate Transparency Act (“CTA”) comes into effect. This sweeping new law imposes significant reporting obligations upon entities that are required to report beneficial ownership and registrant information to the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”). On September 29, 2022, FinCEN adopted its long-awaited final rule (the “Final Rule”) to implement the beneficial ownership reporting requirements of the CTA, although reporting forms and methodology are currently being finalized.