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A step forward for corporate transparency company." Further details on the final rule and who it
affects can be found here: https://bit.ly/3TkSwH3.
he Corporate Transparency
Act's final rule was issued in Given that a primary objective of the CTA is to make money
September. Can you explain what laundering activities more difficult while making it easier
T it entails and what the impact to catch criminals engaged in it, this is good news for
might be? I figure it will be good for payments and fintech honest professionals in the payments/fintech ecosystem.
companies overall. Do you? This will, however, impact partnerships and mergers and
Brett Gaire acquisitions. Added to due diligence tasks will be checking
Underwriting Trainee to see that potential partners or acquisitions have complied
Brett, with the new reporting requirements under the CTA.

The Corporate Transparency Act, (CTA) which became Also, law enforcement agencies are expected to use
law in January 2021, requires companies to disclose to the increasingly sophisticated data mining tactics to flag
U.S. government the names of their true owners. It was suspicious activity among data FinCEN will collect. This
devised to thwart drug traffickers, oligarchs, fraudsters means a percentage of honest companies will be swept
and other criminals that have used shell companies and into AML investigations, along with criminal enterprises.
front companies to hide ill-gotten gains from the federal This will be an unwelcome, but likely unavoidable burden
government. on law-abiding companies that are targeted.
The U.S. Treasury’s Financial Crimes Enforcement Thank you for your inquiry, Brett. Good luck in your
Network (FinCEN) issued its Final Rule for implementation underwriting career.
of the act's requirement to report beneficial ownership Editor
information. Beneficial owners, according to reporting
from Foley & Lardner LLP, are “any individual who, CTA's impact
directly or indirectly, either exercises substantial control Is your company among the millions that will be required
over such reporting company or owns or controls at to comply with the CTA? Let us know how you're
least 25 percent of the ownership interests of such report addressing it at greensheet@greensheet.com.