USA finally introduces its own UBO register

On 1 January 2024, the Corporate Transparency Act will enter into force. In an effort to combat money-laundering, terrorism, tax evasion, and other financial crimes, the Act creates a national database of owners and people in control positions of U.S. companies. See our article "The US ends corporate anonymity".


This law will apply to almost all domestic LLCs (including single-member LLCs), corporations, limited partnerships, and other closely held entities. It will also apply to foreign LLCs (including single-member LLCs), corporations, limited partnerships, and other closely held entities that are registered to do business in any state.

The companies will need to report their beneficial owners to the Financial Crimes Enforcement Network (“FinCEN”) with their full legal name, their birth date, their home address (not a P.O. box or the address of an attorney or another adviser) and a photocopy of the individual’s US passport or state driver’s license.

Entities that are already subject to significant reporting requirements are exempt, such as banks and other financial institutions, insurance companies, investment companies, and advisers, brokers and dealers in securities, …

For existing entities, initial reports are due by 1 January 2025. For entities created on or after 1 January 2024, initial reports are due within ninety days of formation. Changes to any of the information filed, including a change of name or address for a beneficial owner, must be reported to FinCen within ninety days.

Anyone who has an interest in - or control over - a reporting company (including any officer, director, manager, chief financial officer or investment trustee) you may be responsible for filing reports with FinCEN.


There are penalties for non-compliance of up to $500 per day (!) for late reporting and up to $10,000 and imprisonment of up to two years for purposefully providing false information, failing to provide complete information, or failing to update information.