In a Law360 article, Sidley lawyers David Buck, Paul Tyrrell, and Michael Mann examine the Financial Crimes Enforcement Network’s (FinCEN) final rule significantly narrowing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA), the law that had required many small and midsize entities to tell the federal government which individuals ultimately own or control them. The authors explain what the rollback means for U.S. companies and their beneficial owners, foreign companies registered to do business in the United States, and financial institutions subject to customer due diligence requirements, and highlight state-level BOI requirements and future FinCEN rulemaking that companies should continue to monitor.
