Toll Free
Toll Free

​

What are the required CTA due dates of FinCEN Reports?

​

Only entities categorized as "Reporting Companies" are obligated to submit a CTA FinCEN report. To ascertain whether an entity falls within the classification of a reporting company, kindly refer to the section titled "Who Must File a FinCEN Report?" Below are the three scenarios and their respective deadlines for CTA FinCEN reports:

​

    1. Reporting companies formed before 2024:

Reporting companies established before the year 2024 must ensure the submission of their initial FinCEN report no later than January 1, 2025.

    2. Reporting companies formed during 2024:

For reporting companies established during the year 2024, the FinCEN report must be filed within 90 days of the entity’s formation or creation.

    3. Reporting companies formed after 2024:

For reporting companies established after the year 2025, the FinCEN report must be filed within 30 days of the entity’s formation or creation.

​

    4. Reporting companies with changes in reported information:

In the event that any information regarding a beneficial owner, as disclosed in a previously submitted FinCEN report, undergoes changes, the reporting company is obligated to file an amended FinCEN report within thirty days following the occurrence of the change. Common instances necessitating an amendment include, but are not limited to:

• A new owner acquiring 25% or more of the reporting company.

• An owner who previously held less than 25% ownership acquiring enough to reach or exceed the 25% threshold.

• A beneficial owner who owned 25% or more passing away, leading to the transfer of ownership and one or more inheritors holding 25% or more of the reporting company.

• A change in the beneficial owner’s address as stated in the most recent FinCEN report (e.g., a change of residence).

• A beneficial owner obtaining a replacement driver’s license, passport, or other document listed in the most recent FinCEN report.

• A person named as a beneficial owner in a FinCEN report ceasing to be a beneficial owner.

 

A beneficial owner is defined as an individual who, either directly or indirectly, exercises substantial control over the entity or owns or controls at least 25 percent of the entity’s ownership interests. This control can be established through various means such as contracts, arrangements, understandings, relationships, or other mechanisms.

​

Amendments to a FinCEN report must be submitted within thirty days following the occurrence that requires the filing of the amended report. Currently, FinCEN does not offer a formal procedure for entities to submit amended FinCEN reports, indicating that reporting companies are unable to submit such reports at this time.

​