An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies need to consider taking prior to the first reporting deadlines to comply with the new requirements.
The reporting requirements take effect January 1, 2024. All non-exempt domestic reporting companies created on or after January 1, 2024, will have 30 days from notification of their formation to file an initial beneficial ownership report with the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN"). Foreign reporting companies formed on or after January 1, 2024, will have 30 days from their initial qualification to do business in a U.S. jurisdiction to file. Domestic or foreign reporting companies in existence prior to January 1, 2024, will have until January 1, 2025, to file an initial beneficial ownership report.
While FinCEN is expected to issue additional interpretative guidance on the reporting procedures, including the format of the reporting form and final rules on access to reported information, companies can take specific steps now to ensure they are ready to timely comply with the new requirements.
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