As we have previously reported, the much-discussed Corporate Transparency Act (sometimes abbreviated as the CTA) will go into effect on January 1, 2024, with the first company reports due 90 days later. The intent of this act is to combat money laundering, terrorist financing, fraud and other illegal activity by creating a place where law enforcement agencies can obtain information about those who own or control privately-held organizations.

The CTA information database will be created by requiring most companies to file online ownership reports with a branch of the U.S. Treasury Department. Federal officials are not planning to reveal the online filing site until the January 1, 2024, effective date, but new regulations and interpretations of the CTA are being issued in rapid succession leading up to that date, and the Bose McKinney & Evans team is monitoring these ongoing developments and preparing to implement filings when they are required.

Any company organized prior to calendar year 2024 has until January 1, 2025, to make these filings. Any company organized during 2024 must make applicable filings within 90 days of the company’s formation date. We expect to be in a position to assist clients in complying with the new requirements early in 2024, well in advance of the date the filings are due. In addition, we expect to reach out in 2024 to our existing clients that were formed before January 1, 2024, and are required to make a CTA filing with information about their filing obligations and options for making those filings before the January 1, 2025, deadline.

In the meantime, the Business Services Group is ready and willing to provide information and guidance about the CTA and its reporting obligations. We strongly encourage our clients to reach out to their attorney contacts with any questions or concerns about their obligations under the Corporate Transparency Act.