Corporate Transparency Act: Time to Begin Preparation

Jonathan C. Wolnik

The Corporate Transparency Act (“CTA”) was enacted on January 1, 2021, effectively requiring most privately held companies to submit identification of their ownership (“Beneficial Owner Information” or “BOI”) to the U.S. Treasury. The stated purpose of the CTA is to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity.” BOI will be reported to, and retained by, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), for law enforcement purposes. The BOI shall not be made public and will not be available pursuant to FOIA requests.