Policy Briefing — U.S. Corporate Transparency Act Enacted

Executive briefing: The Corporate Transparency Act (CTA) became law on January 1, 2021 when the U.S. Congress overrode a presidential veto to enact the National Defense Authorization Act for Fiscal Year 2021 (Public Law 116-283). Beginning January 1, 2024, most corporations, LLCs, and similar entities created or registered in the United States must submit beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN).

Immediate compliance priorities

Entity scoping. Catalogue legal entities to determine which qualify as "reporting companies" and which fall within statutory exemptions.
Data collection. Identify beneficial owners and company applicants, gathering required identifiers (name, date of birth, address, passport or driver licence numbers) for reporting.
Governance updates. Assign responsibility for ongoing CTA compliance, including processes to update FinCEN within 30 days of ownership or detail changes.

Control alignment

Policy integration. Incorporate CTA obligations into AML programs, customer due diligence playbooks, and new-entity onboarding workflows.
Record retention. Implement secure repositories for beneficial ownership attestations, supporting audit trails and confidentiality requirements.
Technology enablement. Prepare system interfaces or vendor solutions aligned with FinCEN’s Beneficial Ownership Secure System (BOSS) specifications.

Enablement moves

Coordinate with legal counsel to interpret exemptions for regulated entities, large operating companies, and tax-exempt organisations.
Engage corporate secretaries and registered agents to build workflows for timely CTA filings at formation.
Develop training for finance, legal, and compliance staff highlighting civil and criminal penalties for willful reporting failures.

Sources

Zeph Tech assists legal and compliance teams with CTA scoping matrices, beneficial ownership data collection kits, and automation options for FinCEN submissions.