Puerto Rican Entities Must Comply with New Financial Crime Reporting Requirements

As of January 1, 2024, Puerto Rico-based entities registered with the Department of State will be subject to new financial crime reporting requirements aimed at combating money laundering and terrorist financing.

What is the Corporate Transparency Act (CTA)?

The CTA requires “Reporting Companies” to file a Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury.

What information must be reported?

• Basic information about the Reporting Company itself
• Beneficial owners and company applicants

Who is considered a Reporting Company?

• Domestic and foreign entities that are corporations, limited liability companies, or other entities created by filing a document with the secretary of state or similar office
• Includes legal entities registered with the Puerto Rico Department of State, unless an exception applies (there are 23 types of exempted entities)

What is considered a beneficial owner?

• An individual who exercises substantial control over the Reporting Company
• Owns at least 25% of its ownership interests

What information must be reported for beneficial owners and company applicants?

• Full legal name
• Date of birth
• Current residential address
• Unique identification number from an acceptable identification document
• Name of the issuing state or jurisdiction

How do I comply with these new requirements?

Puerto Rico entities should review these new rules and develop a plan to ensure compliance. RSM Puerto Rico tax advisors are available to provide additional information and advice on how to navigate these requirements.

Contact us for more information:

• Phone: (787) 751-6164
• Email: email protected

Take the first step in ensuring your entity’s compliance with these new financial crime reporting requirements. Contact RSM Puerto Rico today!