Effective January 1, 2024, the Corporate Transparency Act (CTA) requires entities formed or registered to do business in the United States to disclose detailed information about their owners, officers, and control persons to the Financial Crimes Enforcement Network (FinCEN).
About the CTA
The CTA aims to enhance transparency and combat money laundering, corruption, and other illicit activities. Noncompliance can result in significant fines and imprisonment. However, there are still uncertainties regarding implementation and enforcement.
How We Can Help:
Our cross-disciplinary team has decades of experience helping companies, governments, and international organizations address compliance expectations faced by global enterprises. We advise on various aspects of CTA compliance including the following:
- Review organizational and ownership structures and provide CTA reporting guidance.
- Develop and implement CTA compliance policies.
- Provide CTA-related trainings and presentations.
- Review current template agreements to add CTA-related safeguards (e.g., engagement letters, officer agreements, purchase-related agreements, bylaws, etc.).
- Evaluate potential reorganization and restructuring opportunities to maximize CTA reporting efficiencies.
- Assist in inventorying existing entities and developing procedures for gathering beneficial ownership information to be reported by January 1, 2025. View our tip sheet here.
- Develop procedures and guides to encourage reportable individuals to obtain FinCEN identifiers.
What You Should Know: