Alerts1.19.24
FinCEN Updates Guidance on Identifying Company Applicants Under the CTA
Highlights
FinCEN issues guidance on reporting company applicants in BOI filings
Attorneys and accountants may be considered reportable company applicants
Updated guidance identifies corporate service companies and other entity registration service providers as company applicants
Neither automated websites nor third-party mailing services reportable as company applicants, but law firm mailroom employees might be
On Jan. 12, the Financial Crimes Enforcement Network (FinCEN) updated its Frequently Asked Questions on Beneficial Ownership Information Reporting to include new guidance aimed at helping reporting companies identify company “applicants” under the 2024 beneficial ownership information (BOI) reporting rule.
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