We are over halfway through 2024 and are rapidly approaching the January 1, 2025 deadline for companies to submit their Beneficial Ownership Information (BOI) reports mandated by the Corporate Transparency Act (CTA).

The CTA requires all domestic and foreign companies (“reporting companies”), excluding tax-exempt entities and those that meet the exemption requirements of the CTA, to file reports with the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) that include information about the reporting company itself and its beneficial owners. Reporting companies must include its name, jurisdiction of formation, Employer Identification Number and address of its principal place of business in the BOI reports. As for each beneficial owner, they must include their name, date of birth, residential address and a copy of their license or passport. Additionally, for reporting companies formed after January 1, 2024, the BOI report must include information about the person who formed the reporting company, known as the company applicant, whether it’s the beneficial owner or their representative.

Reporting companies that existed before January 1, 2024, have until January 1, 2025 to submit their initial BOI reports. However, reporting companies formed after January 1, 2024 have 90 days from their date of formation to submit the report. Additionally, reporting companies will have a 30-day window to submit supplemental reports to correct inaccuracies or provide changes to the submitted information.

Given these requirements and the penalties that the CTA imposes for non-compliance, including civil and potential criminal penalties, it is imperative that businesses begin the process of complying with the CTA. Cohen Seglias’ Business Transactions Group is available to assist clients in complying with the CTA, and the preparation and filing of the BOI reports.