November 30, 2023

The Financial Crimes Enforcement Network (FinCEN) published a final rule amending its September 30, 2022 beneficial ownership “Reporting Rule” to extend the filing deadline for certain beneficial ownership reports. We provided details on this amendment when it was originally proposed on September 28, 2023.

Under FinCEN’s September 30, 2022 Reporting Rule, entities created or registered on or after the rule’s effective date of January 1, 2024 were originally required to file initial reports with FinCEN within 30 days of notice of their creation or registration. This new amendment extends that filing deadline from 30 days to 90 days for entities created or registered on or after January 1, 2024 and before January 1, 2025 “to give those entities additional time to understand the new reporting obligation and collect the necessary information to complete their filings.” Entities created or registered on or after January 1, 2025 will have 30 days to file their beneficial ownership reports with FinCEN, in line with the original requirements of the September 2022 Reporting Rule. Moreover, the amendment does not impact the January 1, 2025 filing deadline for entities created or registered before the Reporting Rule’s January 1, 2024 effective date.

SWACCA has been deeply engaged on FinCEN’s beneficial ownership rulemaking, including securing provisions in the initial rulemaking implementing the beneficial ownership reporting regime that ensured many SWACCA members and affiliates will be exempt from reporting their beneficial owners. SWACCA has also been advocating to ensure the beneficial ownership database can be used to pursue misclassification investigations.

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