Jamie L. Boucher, Alessio Evangelista, Eytan J. Fisch, Greg Seidner and Javier A. Urbina

Skadden Discusses Final FinCEN Rule on Beneficial Ownership Reporting

By by

On September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a long-awaited final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (CTA). The final rule adopted much of FinCEN’s December 8, 2021, proposed BOI reporting rule, though FinCEN made several notable amendments in the final rule.1

Among other things, the final rule:

  • adjusts some of the reporting timelines established in the proposed rule;
  • does not recognize additional types of entities that are exempt from the CTA’s reporting requirements, but clarifies the application of certain exemptions and that no filing

… Read more