With recent headlines dominated by the ongoing pandemic and the raid on Capitol Hill, many practitioners may have missed Congress’ recent enactment of the Corporate Transparency Act (CTA) as part of the most sweeping anti-money laundering legislation in decades. Practitioners in Florida should be familiar with the reporting obligations and potential penalties under the CTA as it will apply to many of the estimated 756,588 domestic Florida corporations and 1,473,881 Florida limited liability companies in the State of Florida as of Oct. 5, 2020.

On Jan. 1, 2021, Congress passed its annual National Defense Authorization Act for Fiscal Year 2021 (NDAA), a national defense-spending bill, over President Donald Trump’s veto. The NDAA includes the Anti-Money Laundering Act of 2020 (AML Act), which significantly reforms current anti-money legislation, including the Bank Secrecy Act (BSA). The AML Act, in turn, includes the CTA, which is aimed at combatting the use of holding or “shell” companies to finance terrorism, launder money and commit other crimes.