On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the federal Corporate Transparency Act’s (CTA) reporting requirements.
The CTA implements sweeping changes in corporate law reporting. The CTA applies to all entities that are created by filing a document with a secretary of state or other similar office of a State or Indian tribe, unless 1 of the 23 exemptions applies. Of note to Alaska Native Corporations, there is no express exemption for ANCs, although we suspect some will qualify for the “large operating company” exemption.
While the CTA reporting requirements are not effective until January 1, 2024, and this date may seem distant on the horizon, companies should start planning for compliance now – including an initial determination of whether an exemption applies. If no exemption applies, or if an exempt company may not be exempt on January 1, 2024, companies need to promptly create a compliance plan, including determining which individual or agent of the company will be responsible for identifying the company’s beneficial owners and any company applicants, collecting the reportable information about each beneficial owner and any company applicants, and filing required reports.
LBB is working to understand how this law impacts our clients and businesses in Alaska. Stay tuned for more on this important new law.
