The Corporate Transparency Act: A Legal, Political, and Regulatory Battle Over Beneficial Ownership Disclosure: Client Alert Digest

Summary

The Corporate Transparency Act (CTA) (31 U.S.C. § 5336), enacted in 2021 as part of the National Defense Authorization Act (116 P.L. 283), was hailed as a landmark anti-money laundering reform. It mandates that certain U.S. and foreign entities disclose their beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN), aiming to curb illicit financial activities facilitated by anonymous shell companies. This measure was widely supported across party lines and by a broad coalition of stakeholders who viewed it as a critical step in strengthening the U.S. anti-money laundering framework. However, a March 2025 Interim Final Rule (IFR) (90 Fed. Reg. 13688), issued by the U.S. Treasury Department (Treasury) has sparked a fierce backlash. This client alert digest discusses the legal, political, and regulatory battle over beneficial ownership disclosure under the CTA and includes links to federal resources, law firm client alerts, news articles, as well as ...