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Thomas is an associate in the firm’s Corporate practice. Thomas graduated from the University of Virginia School of Law, where he served on the editorial board of the Journal of Law and Politics and participated in the transactional-focused Nonprofit Clinic.

On November 8, the Financial Crimes Enforcement Network (FinCEN) issued a final rule outlining the conditions under which a reporting company can report another entity’s FinCEN identifier instead of an individual’s beneficial ownership information (BOI). A FinCEN identifier is a unique number issued by FinCEN to an individual or a reporting company that has provided its BOI to FinCEN.

Yesterday, the Financial Crimes Enforcement Network (FinCEN) published a Small Entity Compliance Guide and updated its list of Frequently Asked Questions (FAQs) to assist entities in determining what steps will be required to comply with the beneficial ownership reporting requirements of the Corporate Transparency Act. The newly published guide includes various flow charts, tables, and hypothetical scenarios that are meant to assist members of the small business community with the analyses all companies must undertake in order to comply with the act, including determining whether a given company is or is not a “reporting company,” and determining each reporting company’s beneficial owners. FinCEN also published new FAQs and revised prior FAQs regarding the act and related reporting mechanics.