On 18th September 2023, FinCEN, the Financial Crimes Enforcement Network, published the Compliance Guide for Small Entities for final beneficiary reporting (BOI) under the Corporate Transparency Act (CTA), and updated the FAQ’s on CTA compliance on FinCEN’s BOI FAQ’s. Professional service providers such as accountants or lawyers could be subject to the reporting requirements under the CTA, even if not…
The news was recently reported by JD Supra. The CTA was enacted with a view to increase transparency and accountability within corporations, and to prevent illicit funds’ entries into the U.S legal system.
Professional service providers such as accountants and lawyers are now potentially subject to these reporting requirements. These requirements could potentially be imposed even if they are not directly engaged in providing services which involve the transfer of funds.
This move implies that corporate lawyers and accountants who were previously exempted from certain compliance procedures could now be brought under FinCEN’s regulation.
This news is significant for corporate and financial law professionals across the globe who maintain partnerships with U.S. based corporations. I strongly recommend all law firms and corporations to review this development and understand its potential implications for their operations and international partnerships.
FinCEN has always focused on encouraging companies to improve their internal record-keeping and update their compliance procedures. It aims to combat money laundering, illegal financial activities, and promote financial transparency in the corporate sector. If you’re a legal professional working with multinational corporations, it’s crucial to understand these upcoming changes and adapt accordingly.
For more detailed information, please refer to the original Informational Guide released by the Financial Crimes Enforcement Network (FinCEN) and the Corporate Transparency Act (CTA) itself.