“FinCEN” filing for Business Entities in 2024 – new U. S. Government requirement.

The Corporate Transparency Act (“CTA”) was enacted January 1, 2021, as part of the
National Defense Authorization Act, representing the most significant reformation of
the Bank Secrecy Act and related anti–money laundering rules since the U.S. Patriot
Act. This email / letter is going out to all our clients so that any clients who may need
to comply with the reporting requirements in this new law are informed.

The CTA is intended to address and guard against money laundering, terrorism
financing, and other forms of illegal financing by mandating certain entities (primarily
small and medium size businesses) to report “beneficial owner” information to the
Financial Crimes Enforcement Network (“FinCEN”). The CTA authorizes FinCEN, a
bureau of the U.S. Treasury Department, to collect, protect, and disclose Beneficial
Ownership Information (BOI) to authorized governmental authorities and to financial
institutions in certain circumstances.

Please note that our firm is NOT handling this process for business entities. We
wanted to alert you as soon as possible about the existence of filing requirements that
we have been made aware of so that you can address it as you deem appropriate for
your business entities. Unfortunately, our office is not in a position to make any legal
determinations about whether or not you are required to file. Please contact your legal
counsel for guidance in these matters. The BOI FAQ website has outlined the following
requirements regarding filing dates:
“A reporting company created or registered to do business before January 1, 2024, will
have until January 1, 2025 to file its initial beneficial ownership information report.”

“A reporting company created or registered on or after January 1, 2024, and before
January 1, 2025, will have 90 calendar days after receiving notice of the company’s
creation or registration to file its initial BOI report.”

Here are links to the FinCEN BOI FAQs and filing website for your reference: