October 17, 2023

In 2021, it came to the attention of the United States Congress that malign actors seeking to conceal their ownership of corporations, limited liability companies (“LLCs”), or other similar entities in the United States were using such entities as vehicles to facilitate illicit activity, including money laundering, the financing of terrorism, serious tax fraud, human and drug trafficking, counterfeiting, and other malicious acts. In an effort to combat such illicit activity, Congress passed the Corporate Transparency Act (“CTA”) which has authorized the Financial Crimes Enforcement Network (FinCEN) to collect ownership data and other personal information from certain corporations and LLCs to create a comprehensive security database which will be accessible only to certain government agents and agencies.


Pursuant to the CTA, beginning January 1, 2024, most small, privately held LLCs and corporations that were formed prior to January 1, 2024 are required by this law to make a filing with FinCEN containing their ownership data and other personal information.


The FinCEN website will be live beginning January 1, 2024. Existing LLCs and other companies that fall under this law are required to make their filing on the FinCEN website by December 31, 2024.


As well, beginning January 1, 2024, the same types of companies and LLCs will be required to make similar filings with FinCEN at the time of formation. These companies are required to make their filing with FinCEN within 30 days of filing a formation document with the relevant state agency (such as a Certificate of Formation).


Please visit our website for further information. 

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