BSA-AML Examiner School eBook

Internal Use Only

Corporate Transparency Act (CTA)

Requirements: • Certain companies in the U.S. to report their BOI to FinCEN. • Reporting requirement will begin on January 1, 2024.

• Law enacted on January 1, 2021 • Part of the National Defense Authorization Act • Aims to enhance transparency & combat ML, TF, corruption, tax fraud, and other illicit activities.

Internal Use Only

Beneficial Ownership Information (BOI) Recent Changes: • FinCEN removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. persons • Set new deadlines for Foreign Companies • Any foreign entity that becomes a reporting company before March 26,2025, is required to file an initial report no later than April 25,2025 • Any foreign entity that becomes a reporting company on or after March26,2025 is required to file an initial report within 30 calendar days of the earlier of the date on which it receives actual notice that it has been registered to do business or the date on which a secretary of state or similar office first provides public notice, such as through a publicly accessible registry, that the reporting company has been registered to do business. • The definition of beneficial owner has not changed, and the bank stills needs to collect beneficial ownership documents during their CIP process for their customers.