Compliance Briefing — January 1, 2021

Executive briefing: The Corporate Transparency Act (CTA) became law on 1 January 2021, directing FinCEN to collect beneficial ownership information from newly formed and existing entities. Companies must prepare to disclose ultimate owners, control persons, and company applicants once implementing regulations commence.

Key compliance checkpoints

Entity scoping. Inventory subsidiaries and affiliates to determine which meet the CTA definition of reporting company and which qualify for exemptions (e.g., SEC registrants, large operating companies).
Beneficial ownership capture. Establish processes to obtain legal name, date of birth, address, and ID numbers for each beneficial owner and company applicant.
Recordkeeping. Maintain secure records of submitted information and supporting documentation for at least five years after any change.

Operational priorities

Systems readiness. Integrate CTA data capture into entity management platforms, ensuring workflows for updates within prescribed timelines once final rules become effective.
Policy updates. Revise AML, KYC, and corporate governance policies to reference CTA definitions, exemptions, and internal attestation requirements.
Advisor coordination. Align legal, tax, and compliance teams to monitor FinCEN rulemaking and prepare for the beneficial ownership database onboarding process.

Enablement moves

Develop owner attestation forms and secure portals for collecting identity documentation.
Automate reminders tied to corporate actions—equity transfers, officer changes, reorganisations—that may trigger CTA updates.
Create board reporting dashboards highlighting readiness gaps, exemptions applied, and pending guidance from FinCEN.

Sources

Zeph Tech readies legal entities for CTA reporting with ownership data pipelines, exemption reviews, and governance dashboards.