ANALYSIS: Treasury Tasked to Fill Transparency Act’s Open Issues

In the newly enacted Corporate Transparency Act, Congress left many open questions for the Department of the Treasury to address in regulations issued before the start of 2022.

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) must now determine the regulatory contours of the new legislation, which are likely to have a significant effect on which entities and owners are impacted—and which, in turn, will in some cases influence whether they maintain their current corporate structure.

While the ownership of affected entities will not become public under the act, this is the first U.S. legislation that requires disclosure ...