You Filed Your Beneficial Ownership Information Report, But Is it Right? An Analysis of Substantial Control

You are likely now aware of the Financial Crimes Enforcement Network’s (FINCEN) new Corporate Transparency Act in effect as of January 1, 2024, that requires domestic entities (and foreign entities qualified to do business in the United States) to file a Beneficial Ownership Information Report (BOI) with FINCEN. In addition, you are also likely aware of your deadlines for filing these reports and FINCEN’s potential fines and possible imprisonment for willfully failing to file or update a BOI.