By SanctionsAI team · Updated 2026-08-09
Corporate Transparency Act (CTA) and beneficial ownership
The Corporate Transparency Act (effective January 1, 2024) requires most US entities to report beneficial ownership information to FinCEN. This creates a national beneficial ownership registry for the first time.
Who must report?
| Entity type | Must report? |
| LLCs, corporations, partnerships | Yes (unless exempt) |
| Large operating companies (20+ employees, $5M+ revenue) | Exempt |
| Publicly traded companies | Exempt (SEC reporting) |
| Banks and credit unions | Exempt (already regulated) |
| Registered investment advisers | Exempt |
What must be reported?
Company information: Legal name, trade names, address, EIN/TIN, jurisdiction. Beneficial owner information: Full legal name, date of birth, residential address, government ID number (passport, driver's license).
Filing deadlines
Entities existing before January 1, 2024: January 1, 2025. Entities formed in 2024: within 90 days of formation. Entities formed after 2024: within 30 days of formation.
Sanctions connection: FinCEN's beneficial ownership registry helps identify OFAC's 50 Percent Rule violations. Financial institutions will gain access to this data for compliance.
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Frequently Asked Questions
- What is the Corporate Transparency Act?
- A 2024 law requiring most US entities to report beneficial ownership information to FinCEN. Creates a national UBO registry.
- Who is exempt from CTA reporting?
- Large operating companies (20+ employees, $5M+ revenue), publicly traded companies, banks, and other heavily regulated entities.
- When is the CTA filing deadline?
- Existing entities (before Jan 1 2024): Jan 1, 2025. New entities in 2024: 90 days after formation. After 2024: 30 days.
- How does the CTA connect to OFAC compliance?
- FinCEN's beneficial ownership registry helps identify entities controlled by OFAC-designated persons under the 50 Percent Rule. Financial institutions gain access for compliance.
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