By: Attorney Thomas A. Griesbach and Attorney Samuel J. Spurney
The Corporate Transparency Act became law on January 1, 2022 and implements Beneficial Ownership Information (“B.O.I.”) reporting requirements on most small businesses in the United States. The Act will create a national database available to law enforcement to crack down on money laundering through “shell corporations”. The reporting requirements will not come into effect until the Treasury issues final regulations on the matter, but all business owners should be ready.
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, issued a notice of proposed rulemaking in December 2021 that proposed some specific rules for the B.O.I. reporting. The public comment period on this proposed rulemaking closed in February 2022. FinCEN anticipates issuing two more notices of proposed rulemaking before issuing final regulations, with one round expected to occur before year’s end. So, the implementation of the reporting requirements will not be immediate, but it is coming.
Following are some important takeaways from the Act and proposed rulemaking to date:
This blog post is provided for informational purposes only and by its very nature is general. Final regulations are yet to be released and may differ from the proposed rules issued to date. This information is not intended as legal advice and should not be relied upon.
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