New Filing Requirements – Corporate Transparency Act

May 15, 2024

The Corporate Transparency Act (CTA) is a recent enactment that mandates increased transparency in entity ownership structures, aiming to combat illicit activities such as money laundering and terrorism financing facilitated by anonymous entities, and has far-reaching implications for entities.  CTA was passed as part of the National Defense Authorization Act for Fiscal Year 2021 but went into effect on January 1, 2024.

The key provisions of the CTA require certain entities to report information about their “beneficial owners” to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.  Beneficial owners are individuals who, directly or indirectly, exercise substantial control over an entity (without or without any entity ownership) or own or control at least 25 percent of the ownership interests of the entity.

Beneficial owner information reports must include entity information such as the entity’s legal name, tax identification number, jurisdiction of formation, and principal address.  The reports must also include beneficial owner information for each individual beneficial owner, including first and last name, residential address, and a photo of either the individual’s driver license or U.S. passport.

Entities formed before January 1, 2024 have until the end of 2024 to file the beneficial owner information report.  Entities formed on or after January 1, 2024 have 90 days from the date of formation to file the information report with FinCEN.  Starting in 2025, this 90-day filing window will be reduced to 30 days.

In addition to initial filing requirements, there are also requirements to update the beneficial ownership information report filed with FinCEN within 30 days of any information on the report changing, including a change of address.

If you would like assistance with CTA compliance, please contact Ruder Ware at or visit Our team is happy to assist you with analyzing your entity’s CTA requirements.

© 2024 Dairy Forward the official newsletter of the Dairy Business Association. Reprinted with permission.

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This document provides information of a general nature regarding legislative or other legal developments, and is based on the state of the law at the time of the original publication of this article. None of the information contained herein is intended as legal advice or opinion relative to specific matters, facts, situations, or issues, and additional facts and information or future developments may affect the subjects addressed. You should not act upon the information in this document without discussing your specific situation with legal counsel.

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