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New FinCEN
Beneficial Ownership
Reporting Requirements

Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners, i.e., the individuals who ultimately own or control the company. They will have to report the information to the Financial Crimes Enforcement Network (FinCEN). FinCEN is a bureau of the U.S. Department of Treasury. This new requirement is part of a broader effort to enhance transparency and combat illicit financial activities. FinCEN issued a final rule implementing the beneficial ownership reporting requirements of the Corporate Transparency Act (CTA).


Please note: FinCEN cannot accept reports before January 1, 2024.


Key points to note:


  1. Reporting Requirements – Companies must submit information about their beneficial owners, including personal details.
  2. FinCEN Identifier – Individuals can directly provide their information to FinCEN and obtain a FinCEN identifier, which can then be used in Beneficial Ownership Information (BOI) reports.
  3. Compliance DeadlinesCompanies formed after January 1, 2024, must file within 90 days of creation or registration. Existing companies formed before January 1, 2024, have until January 1, 2025, to file their initial reports.
  4. Exemptions and Additional Guidance – Specific exemptions apply, and further guidance is available in the Small Entity Compliance Guide on the FinCEN website.


Important takeaways:


  • Existing reporting company created or registered to do business in the United States before January 1, 2024, must submit reports by January 1, 2025.
  • Reporting companies created or registered on or after January 1, 2024, and before January 1, 2025, have 90 calendar days after receiving actual or public notice that their company’s creation or regulation is effective to file their initial BOI reports.


We recommend reviewing these new regulations and preparing accordingly. Our Team is available to assist with any questions or compliance needs you may have.


For more information, please visit the links below.


FinCEN’s BOI Webpage:


Small Entity Compliance Guide: