Compliance Briefing — September 30, 2022
FinCEN issued its final beneficial ownership information reporting rule on 30 September 2022, setting January 2024 effective dates for reporting companies under the Corporate Transparency Act.
Executive briefing: FinCEN finalised the Beneficial Ownership Information Reporting Requirements rule on 30 September 2022. Reporting companies created on or after 1 January 2024 must file beneficial ownership reports within 30 days of formation (extended to 90 days for 2024 incorporations), while existing entities must report by 1 January 2025.
Key compliance checkpoints
- Reporting scope. Determine whether entities meet the CTA definition of reporting company and confirm exemptions.
- Owner data capture. Collect name, date of birth, address, and identifying numbers for beneficial owners and company applicants.
- Update obligations. Implement change management to update reports within 30 days of ownership or information changes.
Operational priorities
- System integration. Embed BOI data capture into entity management and onboarding platforms ahead of 2024 effective dates.
- Policy alignment. Update AML and corporate governance policies to incorporate CTA reporting requirements and penalties.
- Training. Educate legal, compliance, and business teams on identifying reportable changes and submission procedures.
Enablement moves
- Deploy workflows for document collection and secure storage of identification data.
- Automate reminders for periodic entity reviews, ensuring reports remain current.
- Create dashboards for board oversight covering reporting status and exemptions.
Sources
- Federal Register: Beneficial Ownership Information Reporting Requirements
- FinCEN final rule fact sheet
Zeph Tech equips corporations with CTA-ready workflows, secure owner data pipelines, and change management tracking.