Effective January 1, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) required certain newly formed and pre-existing entities to submit information regarding their beneficial owners and certain controlling parties in a report (“BOI Report”) pursuant to the Corporate Transparency Act (the “CTA”). Entities formed on or after January 1, 2024 and prior to January 1, 2025 have 90 days from formation to submit a BOI Report, while entities formed prior to January 1, 2024 have until January 1, 2025 to comply. Entities formed prior to January 1, 2024 are encouraged to consider whether filing a BOI Report will be necessary, and if so, prepare to file in order to meet the approaching January 1, 2025 filing deadline. Entities formed on or after January 1, 2025 will have 30 days from formation to submit a BOI Report and all Reporting Companies have an ongoing obligation to update beneficial ownership information in connection with any changes to the information initially submitted to FinCEN. Despite the hope of some that the CTA would be deemed unconstitutional or amended to provide for extended deadlines, there has not yet been any action which eliminates or delays the compliance requirements.
