CSG Law Alert: FinCEN Extends Reporting Obligations for Entities Formed After January 1, 2024

As a reminder, and discussed in our earlier CSG Law client alert, The Corporate Transparency Act: How Will It Impact Your Business?, as of January 1, 2024 the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) will require certain companies to report to FinCEN beneficial ownership information on individuals who directly or indirectly own or control reporting companies in the United States as a part of the Corporate Transparency Act (the “CTA”). All domestic and foreign corporations, limited liability companies, or similar entities created by the filing of a document with a secretary of state or similar office will be subject to the reporting requirements of the CTA, unless they meet a specified exemption.

As of November 29, 2023, FinCEN extended the deadline for filing initial beneficial ownership information reports under the CTA for entities created between January 1, 2024 and December 31, 2024 from thirty (30) days to ninety (90) days. This extension applies to both domestic and foreign reporting companies that are created or registered to do business in any state in the United States between January 1, 2024 and December 31, 2024. Reporting companies created or registered to do business in the United States before January 1, 2024 still have until December 31, 2024 to file their initial beneficial ownership information reports.

For more information on the CTA, please visit the FinCEN website at Beneficial Ownership Information Reporting | FinCEN.gov. If you have any further questions, please contact your CSG attorney or the authors listed below.

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