Financial Crimes Enforcement Network official Barry Emmert today previewed the implementation process for the Corporate Transparency Act, an ABA-backed bill that was included in a broader package of Bank Secrecy Act/anti-money laundering reforms that Congress passed in December. “When we think about CTA, we sort of break it down into three different tranches,” said Emmert, at an industry event. “We anticipate it’s going to take those three tranches to implement the [CTA] and in each case, FinCEN will give public notice and invite comment.”
In the coming months, the first part of the implementation process will cover the beneficial ownership reporting requirements, with a rule expected to be issued by Jan. 1, 2022. The second part of the process will involve the creation of a beneficial ownership database—something ABA has long supported.
FinCEN will also focus on additional regulations to address access and disclosure protocols for the beneficial ownership database, Emmert said. Finally, the third phase of the CTA implementation process will involve updating the customer due diligence rule and looking at any existing requirements that may be unnecessary in light of the recent changes.