The beneficial ownership reporting requirements imposed by the Corporate Transparency Act, or CTA, are now in effect. 31 U.S.C. § 5336. The Financial Crimes Enforcement Network, or FinCEN, estimates tens of millions of existing companies will be reporting soon—in addition to the two million new entities created each year and their “company applicants.” “Willful” failures to comply could result in civil and criminal penalties.

While many practitioners know the CTA and related rules adopted by FinCEN require disclosure of certain information about entities and beneficial ownership information, many are just now realizing how broad and far-reaching those reporting requirements are. Unfortunately, as they grapple with the rules, they are finding that many questions about how to apply the rules in practice are not answered. We cannot canvass all the intricacies of these laws in the compress of a blog post, but we will provide a simple overview of the law and some ideas about what practitioners should be doing now.