FinCEN Required Beneficial Ownership Information

As explained in a FinCEN release, the bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information about the individuals who ultimately own or control them.

Companies that are required to comply (“reporting companies”) must file their initial reports by the following deadlines:

• Existing companies: Reporting companies created or registered to do business in the United States before January 1, 2024 must file by January 1, 2025.
• Newly created or registered companies: Reporting companies created or registered to do business in the United States in 2024 have 90 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective.

Beneficial ownership information reporting is not an annual requirement, explains FinCEN. A report only needs to be submitted once, unless the filer needs to update or correct information. Generally, reporting companies must provide four pieces of information about each beneficial owner:

• Name
• Date of birth.
• Address.
• The identifying number and issuer from one of various acceptable government documents, as specified on the FinCEN site.

Key information to provide

The company must also submit certain information about itself, such as its names and address. In addition, reporting companies created on or after January 1, 2024, are required to submit information about the individuals who formed the company (“company applicants”).

Note that this article is just a summary. The provisions are complex and you probably want to get advice from a qualified professional. More details are available on FinCEN website.