New requirement for most businesses beginning Jan. 1, 2024

Beginning on Jan. 1, 2024, Congress will impose anew requirement in a statute called the Corporate Transparency Act (CTA), which is mainly an anti-money laundering law. The CTA requires many corporations, limited liability companies and other entities created or registered to do business in the United States to report information about their beneficial owners—the persons who ultimately own or control the company—to the U.S. Department of the Treasury’s Financial Crimes EnforcementNetwork (FinCEN).

Every “domestic reporting company” is required to file a Beneficial Ownership Information (BOI) report.  On the report, a reporting company must state its name and provide the following pieces of information for each of its beneficial owners: full name, birthdate, current residential address, and a unique identifying number, along with an image of a state or local ID document,U.S passport, or driver’s license that displays the identifying number.

A domestic reporting company created before Jan.1, 2024 must file its initial BOI report no later than Jan. 1, 2025. Any domestic reporting company created after Jan. 1, 2024 must file a BOI report within30 calendar days of the date it receives actual or public notice that its creation has become active. After the initial filing, whenever a change occurs or an error is discovered, the entity will have 30 days to file an updated report.  The BOI report can be filed electronically through a system that will be available on theFinCEN’s website.