November 30, 2022

Volume XII, Number 334

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November 29, 2022

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November 28, 2022

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Corporate Transparency Act – FinCEN Issues Final Rule for Beneficial Ownership Reporting

We recently shared an alert covering The National Defense Authorization Act for Fiscal Year 2021 (NDAA), which became law on January 1, 2021. The NDAA included significant reforms to the U.S. anti-money laundering and countering the financing of terrorism regime. Division F of the NDAA consists of the Anti-Money Laundering Act of 2020, which includes the Corporate Transparency Act (CTA). Congress enacted the CTA to establish uniform beneficial ownership information reporting requirements to improve transparency for national security, intelligence, and law enforcement agencies in their efforts to detect and prevent money laundering and terrorist financing.

On September 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued regulations regarding the beneficial ownership reporting requirements. The final rulemaking is effective January 1, 2024. Reporting companies created or registered before January 1, 2024, will have one year (until January 1, 2025) to file their initial reports, while reporting companies created or registered after January 1, 2024, will have 30 days after creation or registration to file their initial reports.

In our recent alert, Corporate Transparency Act: FinCEN Issues Final Rule for Beneficial Ownership Reporting, we detail the background of the CTA, what it requires, penalties for non-compliance, and how reported information may be used.

© Copyright 2022 Squire Patton Boggs (US) LLPNational Law Review, Volume XII, Number 280
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About this Author

Rebecca Worthington, Squire Patton Boggs Law Firm, Washington DC, Corporate Law Litigation Attorney
Senior Associate

Rebecca Worthington’s practice focuses on litigation, investigations and white collar criminal defense. She has experience in defending cases brought under the False Claims Act and representing clients in internal and government investigations, including matters involving economic sanctions and the Foreign Corrupt Practices Act. She has been named a Washington DC Super Lawyers – Rising Star, among the top up-and-coming lawyers, defined as 40 years of age and younger or in the practice of law for less than 10 years.

202-626-6654
Benjamin D. Wood Partner  Washington DC Litigation Government Investigations and White Collar Crime
Partner

Ben Wood assists clients in federal and state litigation at the trial and appellate levels, and in government investigations and enforcement matters. Ben has represented financial institutions, corporations, individuals, political organizations, campaigns and foreign governments in matters involving economic sanctions, money laundering, bank fraud, Bank Secrecy Act, public corruption, industrial disasters, healthcare fraud and campaign finance litigation.

202-457-6685
Adam Klauder Government Investigations Lawyer
Partner

Adam Klauder is a partner in the Government Investigations & White Collar Practice.

Adam’s practice focuses on risk management, complex global investigations, financial crime compliance and white collar criminal defense. He advises financial institutions, corporations, governments and individuals on compliance and enforcement matters involving economic sanctions, export controls (EAR/ITAR), anti-money laundering (AML), anticorruption (FCPA) and other cross-border regulatory regimes. Adam represents clients in front of a wide range of...

202-457-6546
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