“As for the CTA, it requires certain “reporting companies” to report the name, date of birth, current address, and unique identification number (from a passport or driver’s license, for example) of their “beneficial owner(s)” to FinCEN. This information must be updated every year to reflect any changes.
Subject to certain exceptions, a “beneficial owner” is defined in the CTA as “any individual who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise:
(i) exercises substantial control over the entity; or
(ii) owns or controls not less than 25 percent of the ownership interests of the entity.”
Moreover, under the CTA, the term “reporting company” means any corporation, limited liability company, or similar entity”
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