On and After January 1, 2024:
- Newly formed small and startup businesses must identify and report “Beneficial Ownership Information” about their directors, senior officers and 25%+ investors within 90 days of formation.
- Small businesses in existence prior to January 1, 2024 must report this Beneficial Ownership Information by December 31, 2024. PLT Pro Tip: Businesses with multiple financing rounds and entity investors should start the more extensive data gathering process soon.
- Failure to comply may result in civil and criminal proceedings, including civil penalties of up to $500 for each day that the violation continues and criminal penalties, including imprisonment for up to two years and/or a fine of up to $10,000. Senior officers of an entity that fails to file a required BOI report may be held accountable for that failure.
To determine if this new law applies to you and for additional information, we recommend contacting Russ Hansen at Prince Lobel via telephone (617.409.6096 – direct dial) or via email (rhansen@princelobel.com).
See our previous Client Alerts on this topic:
- February 10, 2022: Prince Lobel Client Alert, “Proposed Regulation Would Require Small Businesses and Owners to be Listed in National Database”
- June 6, 2023: Prince Lobel Client Alert, “What Your Small Business Has to Disclose Under the Corporate Transparency Act”
- 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”