Global Financial Integrity

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Global Financial Integrity Welcomes Treasury Department NPRM to Implement the Beneficial Ownership Reporting Requirement


WASHINGTON D.C. – Global Financial Integrity (GFI) welcomes the Treasury Department’s Notice of Proposed Rulemaking (NPRM) to implement beneficial ownership reporting requirements as directed by the Corporate Transparency Act (CTA). The CTA was passed last year to, among other things, ensure that individuals who own or control companies are known to law enforcement and tax authorities.  The NPRM was issued after an 11-month commentary and review period by Treasury.

Global Financial Integrity President & CEO Tom Cardamone said today that “we applaud the Treasury Department’s speedy yet detailed clarification of key components of the CTA which we see as important additions and reflective of the commitment that the administration has to the issue.” Further, Cardamone noted that “GFI is looking forward to providing our inputs and working with FinCEN on the critically important implementation process”

The timely release of the new rule is significant because millions of opaque corporate entities  that attract illicit wealth from overseas continue to be registered and incorporated in the U.S., making it easier to open a company than it is to acquire a library card in any one of the 50 states.

Among the most notable requirements under the proposed rule include the reporting of the residential address of each beneficial owner. While the CTA left ambiguous whether a residential or business address was adequate for reporting purposes FinCEN, the Treasury Department’s financial crime-fighting unit, determined that requiring the residential address “is appropriate” given the need to ensure correct tax residency.

While no provision was made to verify the information being providing in the new FinCEN database, the NPRM noted that “the [Treasury] Secretary, in consultation with the Attorney General, will conduct a study no later than two years after the effective date of the BOI reporting final rule, to evaluate the costs associated with imposing any new verification requirements on FinCEN and the resources necessary to implement any such changes.”

Cardamone urged that this two-year timeline be eliminated and that the evaluation should begin immediately. Without verification false names, addresses and other information can be provided and FinCEN would never be the wiser. For the database to be effective the information in it must be accurate.”


ABOUT GFI: Global Financial Integrity (GFI) is a Washington, D.C.-based think tank, producing high-caliber analyses of illicit financial flows, advising governments on effective policy solutions and promoting pragmatic transparency measures in the international financial system as a means to improve global development and security and reduce inequality.

Lauren Anikis – Communications Coordinator
Phone: (202) 293-1720