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Client Alert - Duty to Communicate Beneficial Owner by 11 December 2023

Client Alert - Duty to Communicate Beneficial Owner by 11 December 2023

By Quorum Studio Legale, 29 Sep 2023

The Decree of September 29, 2023 of the Ministry of Enterprises and Made in Italy concludes the long and troubled regulatory process for the establishment of the Register of Beneficial Owners introduced by Legislative Decree no. 90 of May 25, 2017, implementing Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.

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The Corporate Transparency Act takes effect on January 1, 2024 – does your company have to report its beneficial owners to the federal government?

Effective on January 1, 2024, the U.S. Corporate Transparency Act (CTA) will require “reporting companies” to disclose to the U.S. government’s Financial Crimes Enforcement Network (FinCEN) details of their “beneficial owners”.

With the CTA, Congress has passed one of the most significant and sweeping laws affecting LLCs and companies doing business in the United States – covering both domestic and foreign entities – in the most aggressive effort to date against illicit terrorist financing, fraud and money laundering.

This client alert discusses the CTA’s reach and exceptions and disclosure obligations, which are retroactive and go well beyond any disclosure previously expected.

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