Article Written by Kelly Del Ponte

The deadline under the Corporate Transparency Act (CTA) for many companies to report information about their beneficial owners—the individuals who ultimately own or control the company—to the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is less than four months away.

Reporting companies that do not fall within the one of the 23 exemptions and were created or registered to do business in the United States before January 1, 2024, must file by January 1, 2025. A reporting company that dissolved or terminated in 2024 must still file a report with FinCEN by the January 1, 2025, deadline.

If you have determined that your company or subsidiary companies are required to report, begin gathering beneficial ownership information as soon as possible to prepare to comply with the CTA by January 1, 2025. Your company will additionally need to gather information about the company itself. Determining who your beneficial owners are and gathering the accompanying personally identifying information of each beneficial owner may be time consuming and administratively burdensome, so it is necessary to begin this process now if you have not done so already.

When in doubt, report. The guidance that FinCEN has issued this year about its reporting rules has suggested that FinCEN is interpreting its rules strictly. Additional information about the CTA, including the definitions of “reporting company” and “beneficial owner” and what information must be reported is available in our previous post and at fincen.gov/boi.