Financial Crimes Enforcement Network (FinCEN) Reporting Requirements

12.5.23

Effective January 1, 2024, virtually all companies (corporations, limited liability companies, limited partnerships) are required to make certain filings. If your company was formed prior to January 1, 2024, then you need to make your filing by January 1, 2025. For companies formed from and following January 1, 2024, then the filing needs to be made withing 30 days following formation.

This is not overly burdensome. Burdensome, yes. Overly burdensome, no.

The following materials are now available on FinCEN’s beneficial ownership information reporting webpage, www.fincen.gov/boi:

As we form new entities in 2024 and beyond, we will assist in making the appropriate filings. For our clients who have existing entities, they can likely handle the reporting requirements on their own (to be done before January 1, 2025), but if you require our assistance, please contact Ross Schwartz or his assistant, Suzy Henline.

If you are asking why this new requirement:

“The Corporate Transparency Act, through its beneficial ownership reporting requirements, provides the historic opportunity to unmask shell companies and protect the U.S. financial system from abuse by money launderers, drug traffickers, sanctioned oligarchs, and other criminals,” said Himamauli Das, Acting Director of FinCEN. “We are committed to making this transparency process as simple as possible, particularly for small businesses who may have never heard of or interacted with FinCEN before.”