The Corporate Transparency Act – Implementation for Investment Funds and Structured Finance

New beneficial ownership information disclosure requirements under the Corporate Transparency Act come into force on 1 January 2024 in respect of all non-exempt entities formed or registered to do business in the US.

Congress passed the CTA in January 2021, requiring the disclosure of a BOI Report by in-scope entities to the US Treasury’s Financial Crimes Enforcement Network (“FinCEN”), to bring the US generally into compliance with international terrorist financing and anti-money laundering standards.   The CTA will have a significant impact on how most US and non-US entities are formed or registered to do business in the US, serving as a new policy tool to assist government authorities with law enforcement and prosecutorial efforts.

In this whitepaper, we examine some key issues for managers and structures from an investment funds and structured finance perspective, detailing the scope of compliance and action required under the CTA.