On September 29, 2022, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its highly anticipated Final Rule implementing the beneficial ownership information (“BOI”) reporting requirements of the Corporate Transparency Act (“CTA”) legislation. The Final Rule brings about the most significant revisions to the U.S. anti-money laundering/countering the financing of terrorism (“AML/CFT”) compliance framework in more than 20 years, implementing sweeping beneficial ownership disclosure requirements applicable to all U.S. companies and foreign companies doing business with or within the U.S.
The Final Rule generally tracks FinCEN’s earlier Proposed Rule from December 7, 2021, discussed in our prior article here, although there have been a few amendments to the earlier proposal. Below we provide a brief summary of key provisions and takeaways from the Final Rule, which goes into effect on January 1, 2024.