ARTICLE
20 September 2023

Corporate Transparency Act Update

SS
Seyfarth Shaw LLP

Contributor

With more than 900 lawyers across 18 offices, Seyfarth Shaw LLP provides advisory, litigation, and transactional legal services to clients worldwide. Our high-caliber legal representation and advanced delivery capabilities allow us to take on our clients’ unique challenges and opportunities-no matter the scale or complexity. Whether navigating complex litigation, negotiating transformational deals, or advising on cross-border projects, our attorneys achieve exceptional legal outcomes. Our drive for excellence leads us to seek out better ways to work with our clients and each other. We have been first-to-market on many legal service delivery innovations-and we continue to break new ground with our clients every day. This long history of excellence and innovation has created a culture with a sense of purpose and belonging for all. In turn, our culture drives our commitment to the growth of our clients, the diversity of our people, and the resilience of our workforce.
As previously reported by Seyfarth, the Corporate Transparency Act ("CTA") will become effective January 1, 2024. While there are exceptions, the CTA applies to most entities with less than 20 employees.
United States Corporate/Commercial Law

As previously reported by Seyfarth, the Corporate Transparency Act ("CTA") will become effective January 1, 2024. While there are exceptions, the CTA applies to most entities with less than 20 employees. Specifically, these entities must file a disclosure as to beneficial ownership and certain other matters with the Financial Crimes Enforcement Network ("FinCEN"). Filing for those entities formed on or after January 2024 is required within 30 days of formation. Entities formed before January 1, 2024, have until January 1, 2025, to file. A link to our prior discussion of the statute can be found here.

Following up on our earlier publication, on September 18, 2023, FinCEN issued Guidelines and FAQs regarding the upcoming changes required by the CTA. There is little new in these materials. However, FinCEN advises that (i) it will not accept any disclosure filings before January 2024, and (ii) the disclosure form which will need to be filed with FinCEN is still being developed. When ready, the form will be available on the FinCEN website.

Links to the materials released by FinCEN on September 18 can be viewed through the Small Entity Compliance Guide and FAQ document.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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