Legal Alert: Corporate Transparency Act Filing Requirements Removed for U.S. Companies

We have been reporting on the Corporate Transparency Act (“CTA”), the related Beneficial Ownership Report regulations at 31 C.F.R. 1010.380 (the “BOI Regulations”) and their legal implications for over a year. Recently, the U.S. Department of the Treasury announced the suspension of enforcement of the CTA against U.S. citizens and domestic reporting companies. Accordingly, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that removes the requirement for all U.S. companies and U.S. persons to report under the BOI reports that were previously required. The only companies now required to report are companies formed under the laws of a foreign country that have registered to do business in the U.S. by filing a document with a secretary of state or similar office. Foreign companies may still be subject to certain exemptions, as previously stated in the BOI Regulations. However, even foreign entities that are required to report will not be required to report any U.S. citizens that are beneficial owners. For more information, please click here.