Reporting Deadlines for the Corporate Transparency Act

The Corporate Transparency Act (CTA) was enacted to combat illicit activities such as money laundering and terrorism financing by increasing transparency in corporate ownership structures. The CTA requires certain entities to report beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN). This article outlines the important deadlines for compliance with its reporting requirements.

Initial Reporting Deadlines

FinCEN began accepting beneficial ownership information reports on January 1, 2024. The deadlines for initial reporting depend on the date of the entity's creation or registration:

• Entities Created or Registered Before January 1, 2024: These entities must file their initial beneficial ownership information report by January 1, 2025.

• Entities Created or Registered Between January 1, 2024, and December 31, 2024: These entities have 90 calendar days from the date they receive actual or public notice that their creation or registration is effective to file their initial report.

• Entities Created or Registered On or After January 1, 2025: These entities must file their initial report within 30 calendar days of receiving actual or public notice that their creation or registration is effective.

Ongoing Reporting Requirements

Entities subject to the CTA must also file updated reports in certain circumstances, including:

• Changes in Beneficial Ownership: If there are changes to the beneficial ownership information previously reported, the entity must file an updated report within 30 calendar days of the change.

• Correction of Inaccuracies: If any previously reported information is found to be inaccurate, the entity must file a corrected report within 30 calendar days of discovering the inaccuracy.

Penalties for Non-Compliance

Failure to comply with the reporting requirements of the CTA can result in significant penalties, including civil and criminal fines. Entities that fail to report beneficial ownership information or provide false information may be subject to fines of up to $500 per day until the information is correctly reported, and individuals responsible for willful violations may face additional fines and imprisonment.

Conclusion

The Corporate Transparency Act introduces crucial transparency measures to combat financial crimes by requiring entities to disclose beneficial ownership information. Understanding and adhering to the reporting deadlines is essential for compliance. Entities should ensure they are prepared to meet these deadlines and file accurate reports to avoid penalties.

Disclaimer

This article provides general information and is not intended as legal advice. Entities subject to the Corporate Transparency Act should consult with an attorney for advice specific to their circumstances.