FinCEN Provides Guidance on Recently Adopted Beneficial Ownership Reporting Requirements

FinCEN provided guidance on recently adopted beneficial ownership information ("BOI") reporting requirements that will become effective on January 1, 2024. FinCEN published Frequently Asked Questions, Key Filing Dates, Key Questions, and Introductory and Informational videos.

The new rules, which implement the BOI reporting provisions of the Corporate Transparency Act, require that many corporations, limited liability companies and other entities created or registered to do business in the United States (each a "reporting company") identify (i) the beneficial owners of the reporting company and (ii) each "company applicant." Company applicant is defined as the individual who files the document that either creates the domestic reporting company or that first registers the foreign reporting company, as well as any individual who directs or controls the filing of such document.

FinCEN indicated that, in the coming months, it will release a Small Entity Compliance Guide, as well as additional guidance on how to submit beneficial ownership information.