Abstract
The federal Corporate Transparency Act, adopted on January 1, 2021 over President Trump's veto, is the product of two decades of proposed federal legislation to combat money-laundering and terrorist financing through anonymous business organizations. When rules are finalized, newly-formed and existing business entities will have to file reports with the Department of the Treasury's Financial Crimes Enforcement Network identifying control persons and beneficial owners of more than 25% of the entity. Unfortunately, and despite the very long gestation period for the Corporate Transparency Act, the act itself raises a large number of questions for which we are awaiting answers. Hopefully the answers will come in rulemaking which must be completed by December 31, 2021. This paper describes a number of the questions for which we are awaiting answers.
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