Effective January 1, 2024, new Treasury regulations under the Corporate Transparency Act (CTA) will require many U.S. entities and foreign entities doing business in the United States to report identifying beneficial owner information to the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). The deadline follows the publication of Treasury’s final regulations on September 30, 2022.

All businesses with US entities (or foreign entities doing business in the United States) will be potentially affected by the CTA requirements, which are by no means limited to fund sponsors. This note, however, focuses particularly on those CTA compliance issues that are especially relevant to investment fund sponsors and private funds