The Corporate Transparency Act (the “CTA”) is in many respects the single largest change to the law of business organizations ever enacted. Prior to the CTA only a few business entities were required to report their ownership to government authorities. As of January 1, 2024, the CTA implements an expansive, integrated reporting mechanism applicable to almost every business in the country, requiring the collection of ownership and control information for submission to a federal database operated by the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).

The CTA is a rapidly evolving area of the law, with new FinCEN guidance impacting regulatory analysis and filing procedures being issued regularly. With that uncertainty as a background, the members of the SKO CTA Practice Group can assist in your compliance with the CTA.  Non-compliance with the CTA may result in severe penalties for the company and its officers, including fines of up to $500 per day for each infraction, civil penalties and even prison for non-compliance.

SKO’s Corporate Transparency Act Practice Group stands ready to address your questions, such as:

• Is your company subject to the CTA’s reporting requirements?
• What information about the company’s beneficial owners needs to be collected for submission to the FinCEN database?
• What is a “FinCEN Identifier”, and how may your company and your beneficial owners utilize a FinCEN ID to restrict the distribution of highly personal identifying information required by the CTA?
• How and when are updated reports required?
• What language should be included in a company’s organizational documents to detail and ensure that the CTA’s requirements are satisfied?

Please reach out to your primary contact at SKO or a member of the CTA Practice Group to start the process of reviewing your compliance with the CTA.