Beneficial Ownership Information Reporting (BOIR) Update – Corporate Transparency Act (CTA)

​Date Recorded: February 1, 2024
Presenter: Mark W. Dever, AAP, CAMS, Director, FORVIS, LLP

“Implementation of the CTA is an intensive process that requires policy teams, economists, regulatory drafters, IT specialists, and public affairs specialists. We are working hard to complete as much of the CTA implementation work as possible within existing resources and staffing. As we enter 2023, however, we will also need to consider trade-offs in implementing this effort in the absence of additional funding, with the goal of making this program as successful as possible.”

Himamauli (“Him”) Das
Acting Director
Financial Crimes Enforcement Network
U. S. Department of Treasury
December 06, 2022

The Corporate Transparency Act (CTA) establishes uniform beneficial ownership information reporting requirements for certain types of corporations, limited liability companies, and other similar entities created in or registered to do business in the United States. The CTA authorizes FinCEN to collect that information and disclose it to authorized government authorities and financial institutions, subject to effective safeguards and controls. On 09/30/22, FinCEN issued the Final Rule implementing the beneficial ownership information reporting requirements. On 12/16/22, FinCEN published a proposed rule (NPRM) that will govern the access to and protection of the beneficial ownership information. This two-hour webinar will discuss both the Final Rule and the proposed Rule to identify how financial institutions will be impacted with the implementation of both, slated for 01/01/24.

Here’s What You Will Learn:

• Beneficial Ownership Information Reporting (BOIR) Requirements – effective date 01/01/24
• Identify the major differences between the existing DFI CDD/Beneficial Ownership requirements and the BOIR Rules under the CTA
• Discuss the comment opportunities in the NPRM – comments due 02/14/23
• Understand the “next-steps” needed for implementation
• Allow time for questions from participants

Recent well-publicized BSA enforcement actions, fines, and deferred prosecution agreements continue to support a climate proving BSA compliance remains of paramount importance to all financial institutions. This two-hour webinar will not only provide the compliance and sales staff with a current update on the implementation of the Corporate Transparency Act but will also discuss other regulatory and legal issues related to anti-money laundering and counter-terrorist financing activities. It will also compliment existing internal education sessions to help meet the annual BSA/AML training requirements for retail, compliance, and internal audit personnel.