The CTA requires companies to file a report with the U.S. Department of the Treasury identifying their individual beneficial owners, as part of a global effort to counter money laundering and terrorist financing.
“For the time being, the only thing that can be done is review the rules adopted by FinCEN in September 2022 under the CTA and evaluate whether and how they will impact the legal entities for which you are responsible, including whether any entities may be exempt from reporting. It would also be advisable to check the FinCEN website from time to time for further developments,” Lamm notes.
Bob Lamm chairs the Gunster’s Securities Law & Corporate Governance practice. Bob previously served as assistant general counsel and assistant secretary of Pfizer. His prior experience includes senior legal positions at W. R. Grace, CA Technologies, and Financial Guaranty Insurance Company. He also has extensive experience with small and mid-cap companies, as well as nonprofit entities. In addition to his role at Gunster, Bob is an independent senior advisor to the Deloitte Center for Board Effectiveness.