Recent FinCEN guidance clarifies reporting expectations under the Corporate Transparency Act and introduces meaningful enforcement risk for incomplete or untimely filings.
On May 1, 2026, the Financial Crimes Enforcement Network released updated guidance regarding beneficial ownership information reporting under the Corporate Transparency Act. The new guidance addresses several questions that have arisen since initial implementation, including the treatment of complex ownership structures, the timing of reporting for newly formed entities, and the scope of the substantial control prong of the beneficial owner definition.
Reporting companies should reassess their compliance posture in light of the updated guidance, particularly with respect to entities with layered ownership structures, trust-held interests, and senior officers whose roles may meet the substantial control test even where formal equity ownership is limited. Andrew & Hopkins advises clients across the financial services, fund management, and corporate sectors on Corporate Transparency Act compliance and is prepared to assist with structural assessments, reporting workflows, and remediation engagements.