New U.S Financial Crimes Enforcement Network Beneficial Ownership Reporting Requirements

The Financial Crimes Enforcement Network of the US Department of the Treasury (FinCEN) published on December 12, 2023 information on Beneficial Ownership Information Reporting (BOI Reporting). 

The BOI Reporting obligation was introduced under the 2021 Corporate Transparency Act and requires certain domestic and foreign companies (reporting companies) to disclose information about the individuals who ultimately own or control the company. 

A reporting company created or registered to do business before January 1, 2024, must file its initial BOI report by January 1, 2025. A reporting company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 calendar days after receiving notice of the company’s creation or registration to file its initial BOI report. Reporting companies created or registered on or after January 1, 2025, will have 30 calendar days from actual or public notice that the company’s creation or registration is effective to file their initial BOI reports with FinCEN.

Your U.S registered company is subject to this new compliance framework anD reporting companies may begin submitting their BOI reports on January 1, 2024. 

Reporting companies must submit their beneficial ownership information to FinCEN electronically through a secure filing system. A BOI report may be submitted by anyone whom the reporting company authorizes to act on its behalf—such as a third-party service provider.