Information and guidance regarding Beneficial Ownership Information Reporting under the Corporate Transparency Act. Click here for the latest updates.

The Corporate Transparency Act (CTA) requires an estimated 32.6 million US and foreign entities to report information about their owners to FinCEN, a bureau of the US Treasury Department. While public companies, regulated entities, and charitable institutions are largely exempt, most private companies fall within the reporting mandate, including many startup companies. The goal of this new mandate is to discourage money laundering and other financial crimes that benefit from anonymity.

Entities comply by filing “Beneficial Ownership Information” (BOI) reports online, disclosing key identifying information not only about the entity but also about certain individuals who own and control the entity. Determining which individuals to report will be a simple matter for many covered entities but quite complex for other entities, depending on the number and nature of the owners and controlling persons. Individuals may opt to limit the circulation of their personal information by obtaining a FinCEN ID.

The constitutionality of the CTA has been challenged, but the standard advice at this point is that entities newly formed during 2024 should abide by the 90-day deadline in the CTA for filing an initial BOI report unless qualifying as an exempt or excluded entity. Entities that existed before January 1, 2024, face a January 1, 2025 deadline.

We at Verrill are available to advise entities regarding CTA compliance, and we have assembled a set of materials and resources, which are referenced below.

Latest Updates from Verrill:

Verrill Resources:

FinCEN Resources: