The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The Proposed Rules would implement the requirements in the Corporate Transparency Act (“CTA”) that certain domestic and foreign entities submit beneficial ownership information and company applicant information to FinCEN.
The Proposed Rules would impose filing obligations on start-up companies, smaller operating businesses, holding companies and other entities that do not fit into one of the exemptions described below. These entities would need to file certain information with respect to beneficial owners and applicants (individuals who do the filings to form or register the entity).
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