FinCEN Beneficial Ownership Reporting Requirements Reinstated: Key Deadlines for Reporting Companies
Although a preliminary injunction had temporarily paused requirements under the Corporate Transparency Act (the “CTA”), a December 23, 2024 decision by the United States Court of Appeals for the Fifth Circuit has reinstated the requirement for certain companies (each, a “Reporting Company”) mandated to continuously report certain “beneficial ownership information” (“BOI”) with the Financial Crimes Enforcement Network (“FinCEN”). Subject to certain exemptions, private fund advisers and the private funds they advise are considered Reporting Companies under the CTA.
In an attempt to address the disruption caused by the injunction, FinCEN has extended certain reporting deadlines, as further set forth in the following link: Beneficial Ownership Information Reporting | FinCEN.gov.
However, the latest deadline before which any Reporting Company created or registered in or before 2024 should file is January 13, 2025.
Key Takeaway: Reporting Companies, including private funds and their advisers (subject to certain exemptions) should act promptly to meet the extended deadline as set forth above.
Riveles Wahab LLP will continue to monitor developments related to the CTA and the Reporting Rule and provide updates as appropriate.
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