In its first step in linking CTA and banking laws, FinCEN recently posted a Notice to Financial Institution Customers regarding reporting beneficial ownership information under the CTA and banking regulations: According to FinCEN, the notice provides answers to key questions about: (1) reporting beneficial ownership information to FinCEN under the Corporate Transparency Act; and (2) providing beneficial ownership information to financial institutions in connection with Federal customer due diligence requirements. QUESTION 1. Will an entity potentially have to provide beneficial ownership information to both FinCEN and a financial institution? ANSWER: Yes. FinCEN and financial institutions both collect beneficial ownership information from entities. However, they collect that information for different reasons and, in some cases, may collect different types of information. If an entity is

Entities terminated in 2024 are required to file Corporate Transparency Act beneficial ownership information reports, as are administratively dissolved entities. The Financial Crimes Enforcement Network (“FinCEN”) recently published updates to its list of Frequently Asked Questions (“FAQs”) to assist entities in complying with the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”). Principal among these updates was FinCEN’s clarifying requirement that business entities terminated in the year 2024 (whether existing prior to 2024 or formed in 2024) are required to file beneficial ownership information reports (BOIR) under the CTA. This filing requirement also expressly includes BOIR filings for administratively dissolved entities. Each of these concepts were the subject of debate as to their applicability under the CTA prior to this FAQ release,