The CTA, which took effect on January 1, 2024, requires specific business entities with 20 or less full-time employees and $5 million or less in gross receipts or sales to regularly report information about their beneficial owners to the Treasury Department’s Financial Crimes Enforcement Network.

Beneficial ownership information refers to identifying information about the individuals who directly or indirectly own or control a company.

Reporting Timeline

• Covered entities in existence prior to January 1, 2024 are required to report by January 1, 2025
  • Businesses covered by this timeline may want to wait to assess the outcome of further litigation, possible legislation or other unknown delays
• Covered entities formed on or after January 1, 2024 are required to report within 90 days of receiving actual or public notice that their company’s creation or registration is effective
  • Due to the shorter designation, businesses covered by this timeline will need to evaluate the legal, regulatory or legislative landscape when determining when to form a new entity
• Covered entities formed after January 1, 2025 are required to report within 30 days of receiving actual or public notice that their company’s creation or registration is effective

Important Exemption

• Entities with more than 20 full-time employees, more than $5 million gross receipts or sales and an operating presence at a physical office within the U.S.

Learn more about beneficial ownership reporting requirements and file your report at the FinCEN website.