FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

With the Corporate Transparency Act (the CTA) becoming effective on January 1, 2024, a final ruling was issued on the Access Rule that establishes the circumstances under which beneficial ownership information (the BOI) may be disclosed to authorized recipients. This alert discusses the key components of the Access Rule, including the security and confidentiality requirements for accessing BOI required to be reported by reporting companies to FinCEN, how BOI access will be implemented, the necessary protections to avoid unauthorized disclosure of BOI, and the acts that may result in violations and penalties under the Access Rule.