Since January 1, 2024, companies operating in the USA have to report information on their beneficial owners and persons with management control to the Financial Crimes Enforcement Network (FinCEN). These "Beneficial Ownership Information Reporting" obligations under FinCEN's new "Corporate Transparency Act" (CTA) are based on a legislative package (National Defense Authorization Act) of the US Congress, which in turn is part of the Anti-Money Laundering Act of 2020.
Where and when do BOI (Beneficial Ownership Reporting) reports have to be submitted?
BOI reports must be electronically filed through FinCEN’s secure e-filing system, which can be found here: Beneficial Ownership Information Reporting
. A Reporting Company formed in 2024 has 90 days after its formation documents are filed to submit an initial BOI report. Reporting Companies already in existence as of the first day of 2024 have until January 1, 2025 to file their initial BOI reports. Reporting Companies formed in 2025 and beyond will have 30 days to file their initial BOI reports. After an initial BOI report has been filed, any changes to the Beneficial Ownership, Reporting Company information, or Company Applicants, as well as corrections to inaccurate previously reported information, will require an updated report within 30 days following the event necessitating the updated BOI report.
If you need further assistance with CTA reporting requirements, please follow this link
and contact Mr. Manny Schoenhuber from Jackson Walker LLP
mschoenhuber@jw.com
