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Updates on USA UBO implementation

Earlier we reported that the Corporate Transparency Act (the “CTA”) establishing the beneficial ownership reporting regime was enacted in the United States at the beginning of 2021. However, the initial ultimate beneficial owner regulations of CTA raised many uncertainties.

Recently, the Financial Crimes Enforcement Network (FinCEN) issued the proposed regulations, which provide clarifications and guidance on some of the uncertainties. Nevertheless, there are still outstanding issues to be solved and the timing of the disclosure requirements will be determined by the effective date of the final regulations. We will keep you posted.