A recent Wall Street Journal Article (https://www.wsj.com/articles/small-businesses-must-now-report-ownership-information-to-the-government-but-many-dont-know-about-it-bb13f2b6) indicated that many companies subject to the ownership disclosure requirements under the Corporate Transparency Act (CTA) were unaware of the requirements. Given that civil and criminal penalties may be imposed for violations of the CTA, it's important that beneficial owners of companies determine whether they are required to comply with the CTA.
On January 1, 2024, a new reporting regime under the CTA required certain entities to file beneficial ownership information reports with the U.S. government. The U.S. Department of the Treasury’s Financial Crimes Enforcement Network has issued regulations providing details on who must file a report, what information has to be reported and when reports must be filed. For beneficial owners, information required to be reported includes full legal name, birth date, current street address, an ID number and an image of the ID document. A company must provide its legal name and any trade or DBA name, address, jurisdiction of formation, jurisdiction where the company first registered to do business in the U.S. (in the case of a non-U.S. reporting company) and tax ID number.
There are exemptions for certain entities (See https://www.loeb.com/en/insights/publications/2023/12/beneficial-ownership-reporting-under-the-corporate-transparency-act-cta-key-questions-answered and https://www.loeb.com/en/insights/publications/2023/12/beneficial-ownership-reporting-under-the-corporate-transparency-act-cta-key-questions-answered), including for publicly traded companies and SEC-registered companies.