On 29 September, FinCEN has published a Final Rule establishing a beneficial ownership information reporting requirement, pursuant to the bipartisan Corporate Transparency Act (CTA).  The Rule will require most corporations, limited liability companies, and other entities created in or registered to do business in the US to report information about their beneficial owners to FinCEN.  Designed to protect US national security and strengthen the integrity and transparency of the US financial system, the Rule is designed to help to stop criminal actors, including oligarchs, kleptocrats, drug traffickers, human traffickers, and those who would use anonymous shell companies to hide their illicit proceeds.  The Rule is effective from 1 January 2024.  Reporting companies created or registered before that date, will have 1 year (until 1 January 2025) to file their initial reports, while reporting companies created or registered after 1 January 2024, will have 30 days after creation or registration to file their initial reports.  Once the initial report has been filed, both existing and new reporting companies will have to file updates within 30 days of a change in their beneficial ownership information.  FinCEN says that it is committed to implementing these statutory obligations in a robust manner while minimising burdens on reporting companies.

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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