As we approach the end of the first quarter of 2024, business entities in the United States should be familiar with their obligations under the Corporate Transparency Act (CTA), which is part of the 2021 National Defense Authorization Act. The CTA requires entities organized by a filing under state or tribal law to disclose beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN) unless otherwise exempt under the regulations implementing the CTA. We have prepared a memo for clients, that describes the reporting obligations and exemptions. There have been two recent developments with respect to the CTA, one of interest to potential reporting entities and one clarification for banks concerning access to the information possessed by FinCEN in the BOI database. Continue reading >