Along with the Anti-Money Laundering Act of 2020, the Corporate Transparency Act of 2020 (CTA) was part of the omnibus National Defense Authorization Act of 2020 and has the potential for some day being significant. But that won’t be any time soon. First, there is an expected one-year period for a new FinCEN rule to be promulgated which is then will have a two-year phase-in before becoming effective (like the 2016 FinCEN CDD Rule). During that time FinCEN will need to build a new national database of companies that will ultimately be accessible only by banks and other regulated firms defined as ‘covered entities’ under the CDD Rule. And even then, only with the consent of the owner and only in the pursuit of CDD on a customer. Have we lost you yet? Learn more about the intricacies of this new requirement and how it may ultimately affect your covered entity. Not a covered entity under the CDD Rule? Fugedaboutit (translation for non-New Yorkers: Forget about it).
1 ACAMS Credit **Please note that ACAMS credit for this virtual event is available to members of the Chapter only.