Small business FinCEN compliance for 2024

This post details the compliance procedure that we will use for our own businesses, affiliates and clients under our control. Others may use a different procedure.

If you own, operate or control a small business corporation or a limited liability company, you may need to file a new report with the federal government this coming year.

Not all small businesses need to file. The exceptions are not covered in this blog post. Also, this post does not cover the determinations of which individuals need to report. Speak with your business accountant or attorney for clarification.

Business information:

All of the information is likely contained in your entity’s “permanent file”, if you keep a traditional business paper or electronic filing system.

  • The legal name of the company
  • Any trade name or “doing business as” name of the company
  • The current street address of its principal place of business
  • The state or tribal jurisdiction of formation, or the state or tribal jurisdiction in which the foreign company first registered
  • The unique identification number of the company from any state or tribal formation document

Individual information:

All of the requirement information is likely contained in your personnel or tax files.

  • The full legal name , date of birth, current address, and unique identification number of each beneficial owner of the company
  • The nature of each beneficial owner’s interest in the company
  • Any changes to the above information within one year of the change

How to manage this information

All information should be kept in a secure location. Accountants and attorneys already have this secure data storage system in place, so the easiest way to manage this information is to outsource the task.

If you have a business accountant or attorney, then presumably your accountant keeps a secure electronic file with all of the business information. No further action should be necessary on your part.

If your accountant handles payroll, benefits, or member/shareholder filings then they may already have all of the individual information.

What you need to do to comply

As a practical matter, most small business can develop an internal policy to check that ownership and contact information is up-to-date. Request an updated copy of each individual’s driver’s license as necessary.

If any individuals use a Post Office Box address, request a physical address.