by Matthew Bisanz, Adam D. Kanter, Brad A. Resnikoff, and Marcella Barganz
From left to right: Matthew Bisanz, Adam D. Kanter, Brad A. Resnikoff, and Marcella Barganz. (Photos courtesy of Mayer Brown LLP)
On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance explaining that the beneficial ownership information (“BOI”) reporting requirement applies to certain legal entities that have been dissolved or otherwise ceased to exist after January 1, 2024. This new guidance dramatically expands the reporting requirement under the Corporate Transparency Act (“CTA”) and raises significant issues regarding compliance and liability for noncompliance.
The new guidance is effective immediately. Persons who own or manage entities that will dissolve in 2024, or have already dissolved this year—or which were not dissolved irrevocably—should review the guidance to determine their reporting obligations.