In view of the coming into force of the beneficial ownership reporting obligation of firms operating in the U.S. on January 1, 2024 (please see EventID 17480 for a detailed description of the upcoming requirements), the Financial Crimes Enforcement Network (FinCEN) has published several documents and even two videos to support small firms in their compliance with the new reporting and notification requirements. Specifically, FinCEN has issued
– a new guide specifically addressed at small firms which explains in plain text and simple, easy-to-read language the key provisions of the new requirement, including the scope of firms the reporting obligation applies to, the information to be reported, reporting deadlines, the filing procedure, and various other related matters;
– an updated set of frequently asked questions (FAQs) which cover issues such as the purpose of the new obligations, the scope of companies subject to the new requirements, the date by which beneficial owners must be reported, or the content of the new beneficial ownership reports;
– a one-page information sheet as regards the filing dates to be observed by in-scope firms;
– a one-page information sheet containing the six most important questions in connection with the new reporting requirement including the following – as quoted:
1. Does my company have to report its beneficial owners?
2. Who is a beneficial owner of my company?
3. Does my company have to report its company applicants?
4. What specific information does my company need to report?
5. When and how should my company file its initial report?
6. What if there are changes to or inaccuracies in reported information?
– An Introduction video to Beneficial Ownership Information Reporting Requirements on the issue; and
– An Informational video concerning Beneficial Ownership Information Reporting Requirements.