Corporate Transparency Act (CTA)

Assisting clients in compliance with new federal reporting requirements on private businesses.

Husch Blackwell has mobilized a working group to assist clients who will be impacted by the new Corporate Transparency Act (CTA) and its reporting requirements. The CTA will take effect January 1, 2024, and mandates the Financial Crimes Enforcement Network (FinCEN) collect information on certain businesses, including beneficial ownership by individuals, and establish a national corporate registry of such information. 

The CTA was enacted by the U.S. federal government to fight illicit activities conducted through shell companies. Most business entities in the U.S. are created pursuant to state law, and there is a considerable degree of variability in those laws regarding their applicable standards of disclosure regarding beneficial ownership. These gaps have long frustrated federal regulatory and law enforcement efforts. With the CTA, Congress has opted for a federalized approach for the reporting of key corporate information.

Our team, which includes regulatory, tax, and corporate attorneys from across the firm, assists clients in understanding their CTA compliance obligations, including high-net-worth individuals and family offices that have traditionally utilized the entity types targeted by the CTA.

Our CTA guide defines key terms and concepts associated with the Act, including which companies must report under the CTA, reporting exemptions, reporting timelines, penalties for noncompliance, and other vital information. The group will provide regular updates, especially during the first year of implementation, as it is expected that FinCEN will propose rules and provide frequent guidance on this new law.