FinCEN Issues Proposed Rules Requiring Certain US and Non-US Legal Entities to Report Beneficial Ownership Information

On December 8, 2021, the US Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking to implement registration and disclosure requirements of the Corporate Transparency Act. The registration requirements proposed will apply to specified US corporate and other legal entities, as well as specified legal entities formed outside the United States that are registered to do business in the United States. The registration and disclosure requirements may be particularly relevant to banks and investment fund structures that establish legal entities in connection with financings and corporate acquisitions. This Legal Update provides background and further detail on the requirements and notes implications for financial institutions.