2-Hour Program

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This Briefing will be 90 minutes in length.

On January 1, 2024, new beneficial ownership information reporting requirements became effective for over 30 million US companies and foreign companies that do business in the United States. Many businesses have been grappling with the ambiguities, gaps, and inconsistencies in the final rule. These issues cannot be resolved through simple compliance guides or overview presentations.

During this session, experienced faculty will discuss:

  • What is a reportable trade name? (5 minutes)
  • What happens if my jurisdiction does not issue tax IDs? (5 minutes)
  • When does an entity exercise governmental authority? (5 minutes)
  • Are deemed bank holding companies and foreign banks exempt? (5 minutes)
  • What is an “Other Exchange Act registered entity”? (5 minutes)
  • Can I be a subsidiary of a financial market utility? (5 minutes)
  • Will a tax-exempt entity be exempt from Day 1? (5 minutes)
  • Can excluded companies be exempt owners? (5 minutes)
  • When do I entirely control a subsidiary? (5 minutes)
  • What does it mean to be “identified” on a Form ADV? (5 minutes)
  • Can I be a voluntary MSB registrant? (5 minutes)
  • What happens if no individual has substantial control? (5 minutes)
  • Who owns an irrevocable directed trust with no identified beneficiaries? (5 minutes)
  • Do the joint ownership rules make every spouse a beneficial owner? (5 minutes)
  • What happens if my ownership interests are freely tradeable? (5 minutes)
  • Do extremely remote conditional rights constitute an ownership interest? (5 minutes)
  • When would I need an entity FinCEN Identifier? (5 minutes)
  • Are companies from CFA countries reportable? (5 minutes)


Who Should Attend: Corporate and transactional attorneys, in-house counsel and compliance personnel with complex issues involving the FinCEN beneficial ownership information reporting requirements

Program Level: Advanced

Prerequisites: None

Advanced Preparation: None


Matthew Bisanz

Mayer Brown LLP

Zila Acosta Grimes

Linklaters LLP

Charles More

Alston & Bird LLP

Credit Details