The information contained in this document is marketing material and for informational purposes only. The information contained in this document is presented without any warranty or representation as to its accuracy or completeness and all implied representations or warranties of any kind are hereby disclaimed. Recipients of this document, whether clients or otherwise, should not act or refrain from acting on the basis of any information included in this document without seeking appropriate professional advice. The provision of the information contained in this document does not establish any express or implied duty or obligation between Citco and any recipient and neither Citco nor any of its shareholders, members, directors, principals or personnel shall be responsible or liable for results arising from the use or reliance of the information contained in this document including, without limitation, any loss (whether direct, indirect, in contract, tort or otherwise) arising from any decision made or action taken by any party in reliance upon the information contained in this document. © The Citco Group Limited, December 2023.
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.