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Corporate Transparency Act Update

Client Alert
December 27, 2023

For a more detailed overview on the CTA, and the changes business owners should expect at the turn of the calendar, click here. A webinar providing further explanation can be viewed here, which was presented December 7.

The Corporate Transparency Act (“CTA”), with an effective date of January 1, 2024, is set to impose strict reporting guidelines on business owners throughout the country.  The below provides a brief update on two aspects of the CTA ahead of its effectiveness next week.

Access and Safeguards Final Rule

On December 21, 2023, the Financial Crimes Enforcement Network issued the final rule setting forth the access and security guidelines (the “Access Guidelines”) related to the CTA.

The Access Guidelines detail six categories of authorized recipients who may access the beneficial ownership reporting information reported by business owners pursuant to the CTA (collectively, “BOI”): (i) federal agencies engaged in national security, intelligence, or law enforcement activity; (ii) state law enforcement agencies; (iii) foreign law enforcement agencies; (iv) financial institutions facilitating compliance with customer due diligence requirements under applicable law; (v) federal functional regulators assisting financial institutions under (iv) above; and (vi) Department of Treasury officers and employees.

Even if an agency is an “authorized recipient” under the Access Guidelines, that agency must satisfy several security and confidentiality requirements to ensure the proper protection of BOI after its receipt.  These recipient agencies are then further prohibited from re-disclosing BOI, unless one of eight enumerated circumstances is present.  Disclosure in violation of the Access Guidelines carries civil penalties in the amount of $500 for each day a violation continues or has not been remedied, and criminal penalties of not more $250,000 or imprisonment for not more than 5 years, or both.

Trend Amongst Service Professionals

Throughout the rulemaking process, it has become clear that the varying levels of analysis required for a given business’ compliance with the CTA is the “practice of law.”  Ohio Revised Code § 4705.07(A)(3) prohibits any person who is not licensed to practice law in the State of Ohio from committing any act that is deemed to be the practice of law.  Actions in contravention of R.C. § 4705.07 carry steep civil penalties.

Recognizing the legal components of the CTA, numerous professional associations throughout the country, including the American Institute of Certified Public Accountants, the Ohio Society of CPAs, and the BDO Alliance USA, have advised their membership to consider speaking with legal counsel for their liability risks associated with CTA reporting.

Service providers should direct their clients to consult with an attorney concerning their reporting obligations under the CTA to avoid any liability for the unauthorized practice of law.

For questions regarding the CTA and how your business should prepare for the new mandatory reporting, please do not hesitate to contact BMD Member Blake Gerney (brgerney@bmdllc.com) or BMD Attorney Jacob Davis (jrdavis@bmdllc.com).

 

Business & Corporate LawEmployement LawCorporate Transparency ActBlake R. GerneyJacob R. DavisBeneficial Ownership Information Reporting
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