3.1 Is my company required to report its company applicants?

Not all reporting companies are required to report their company applicants to FinCEN.

A reporting company is required to report its company applicants if it is either a:

• domestic reporting company created on or after January 1, 2024; or
• foreign reporting company first registered to do business in the United States on or after January 1, 2024.

A reporting company is not required to report its company applicants if it is either a:

• domestic reporting company created before January 1, 2024; or
• foreign reporting company first registered to do business in the United States before January 1, 2024.

Chart 5 - Company applicant reporting requirementThe special rule concerning company applicant reporting can be found at 1010.380(b)(2)(iv) and is discussed further in the next chapter (section 4.2).