Clifford Chance

FINCEN Has Begun Accepting Beneficial Ownership Interest Reports Under The Corporate Transparency Act

February 16, 2024

On January 1, 2024, the Financial Crimes Enforcement Network, a bureau of the U.S. Department of the Treasury, began accepting online filings of beneficial ownership interest reports pursuant to the Corporate Transparency Act.  BOI reporting requirements under the CTA generally apply to any entity that, through filing a document with a secretary of state or similar office of any U.S. State, is either formed or registered to do business. The CTA provides for 23 categories of legal entities that would be considered exempt from the CTA's reporting obligations, including, among others, public companies, large operating companies, banks, securities brokers or dealers, insurance companies, registered investment companies and advisers, and pooled investment vehicles.

This briefing provides a general introduction to BOI reporting requirements and certain exemptions that we believe will likely apply to many of our clients.

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