ICSC sent this out as a reminder that most companies will have to report by JANUARY 1 or face fines and jail time to make sure all your entities are reported before the deadline.

January 1 Deadline Approaches for Reporting Beneficial Ownership Information ...

November 14, 2024

The Corporate Transparency Act went into effect earlier this year and requires an estimated 32 million small business owners to file certain personally identifiable information with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) by January 1, 2025.

The CTA applies to privately held and many non-profit entities, including corporations, limited liability companies, limited partnerships, business trusts and other similar entities that are created by the filing of a document with a secretary of state or similar governmental office.

As a general rule, businesses not meeting one of several exceptions have to report for their beneficial owners and control persons, certain personally identifiable information (PII) to the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). This PII will include the individual’s full legal name, date of birth, physical residential street address, government issued ID number and a photograph of the government ID. This information must be reported for each “beneficial owner” of the business and for anyone exercising “substantial control” over the business.

Both the beneficial ownership and substantial control analyses are complex, and ICSC members should consult with their legal counsel to determine if their interest in a given business entity requires their PII to be reported.

For those who do need to comply with the law's requirement, reports can be filed at https://boiefiling.fincen.gov/.