Getting your house in order before January 2024. 29 March 2023

Topic:

• The Corporate Transparency Act’s new beneficial ownership information reporting rule: getting your house in order before January 2024

Description:

Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule last fall requiring that all corporations, LLCs, and certain other legal entities report their beneficial ownership information to the government, effective January 1, 2024. There are 23 exemptions, and beneficial ownership is defined by substantial control and ownership interests. Former FinCEN Deputy Director AnnaLou Tirol, now a Partner at O’Melveny & Myers LLP, will discuss preparation for CTA compliance and strategies for planning ahead of the effective date.

The Speaker:

• AnnaLou Tirol – Partner, O’Melveny & Myers, LLP

AnnaLou Tirol counsels clients on anti-money laundering (AML) and fintech regulatory, compliance, and enforcement issues, drawing on two decades of government experience, most recently as Deputy Director of the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

Few lawyers share AnnaLou’s deep familiarity with AML laws and regulations. As FinCEN’s Deputy Director, the bureau’s second highest official, AnnaLou oversaw FinCEN’s operations, programs, and policy, including legislative and regulatory matters, public-private partnerships with financial institutions and fintechs, and enforcement and compliance matters related to the Bank Secrecy Act (BSA). Following Congress’ January 2020 enactment of the Anti-Money Laundering Act of 2020, AnnaLou led FinCEN’s implementation of the most significant legislation to modernize the BSA since the USA PATRIOT Act, including the Corporate Transparency Act’s beneficial ownership requirements.