Compliance Briefing — January 1, 2024

Executive briefing: Beginning 1 January 2024, the Financial Crimes Enforcement Network (FinCEN) accepts Beneficial Ownership Information (BOI) reports mandated by the Corporate Transparency Act. Domestic and foreign reporting companies must disclose beneficial owners and company applicants via the BOI e-filing system.

Key compliance checkpoints

Filing deadlines. Entities created or registered on or after January 1, 2024 must file within 90 days of formation (30 days starting in 2025); existing entities have until 1 January 2025.
Beneficial owner identification. Capture legal name, date of birth, residential address, and identification documents for individuals owning or controlling 25% or more or exercising substantial control.
Change management. Update BOI filings within 30 days of changes (ownership, address, identification numbers).

Operational priorities

Entity scoping. Inventory subsidiaries and investment vehicles to determine reporting company status and exemptions.
Data governance. Establish secure processes to collect and store identification documents, leveraging FinCEN identifiers when available.
Governance oversight. Assign accountable owners (legal, compliance, corporate secretary) to monitor filings, deadlines, and change triggers.

Enablement moves

Integrate BOI reporting into entity management systems and workflow tools to automate reminders and approvals.
Coordinate with external counsel and registered agents to streamline submissions for large entity portfolios.
Document evidence supporting exemption claims (e.g., large operating company, SEC reporting issuer) for audit readiness.

Sources

Zeph Tech operationalises CTA compliance with entity scoping, data collection workflows, and governance dashboards that keep BOI filings current.