As a reminder, pending a ruling by the Fifth Circuit Court of Appeals, small businesses in existence prior to January 1, 2024 must identify and report “Beneficial Ownership Information” about their directors, senior officers and 25%+ investors by December 31, 2024.
A person who willfully violates the Act’s beneficial ownership reporting requirements may be subject to civil penalties of up to $591 for each day that the violation continues and may also be subject to criminal penalties of up to two years imprisonment and a fine of up to $10,000.
Please note, however, that as a result of court proceedings, FinCEN has issued an alert indicating that no filings are currently required, pending the decision of the Fifth Circuit Court of Appeals. Depending on the decision of that Court, this stay of the filing requirements could change as early as this week. FinCEN remains open for voluntary filings, and we encourage those clients who would prefer to wait to be prepared to file. We are continuing to closely monitor the situation.
Read more about the CTA Reporting requirements on The Deal Corner: Prince Lobel’s Business Advisory Blog, or in previous Client Alerts on this topic:
- December 16, 2024: The Deal Corner Blog Post, 2024 CTA Report Deadline Might Be Reinstated This Week or Next
- December 13, 2023: Prince Lobel Client Alert, Important Reminder: The Corporate Transparency Act Goes Live On January 1, 2024
- November 13, 2023: Prince Lobel Client Alert, For Real Estate Promoters, Investors and Professionals, FinCEN’s Two-Pronged Focus to Detect Fraud and Money Laundering is Imminent
For questions about the Corporate Transparency Act, if it applies to you, and how to report, please reach out to Russ Hansen, or any member of Prince Lobel’s Business Transactions Practice Group.