The Corporate Transparency Act (CTA) requires most LLCs to report their beneficial owners to FinCEN. A beneficial owner is any individual who (a) exercises substantial control over the entity or (b) owns or controls 25% or more of ownership interests.

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Initial report

Due: Within 90 days of formation (for entities formed in 2026+). Contents:
  • Entity name, EIN, Wyoming SOS formation number
  • For each beneficial owner:
    • Full legal name
    • Date of birth
    • Address
    • Government-issued photo ID number + image

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Ongoing reporting

Due: Within 30 days of any change in beneficial ownership. Examples of reportable changes:
  • New member acquires >= 25% interest
  • Existing member exits
  • Member information updates (legal name change, address change)
  • New person acquires substantial control (even at < 25% ownership)

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How Orgs handles it

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Initial filing

During formation, we collect beneficial owner data in a PII-safe flow (see PII handling). Once the entity is formed, we file the initial BOI report with FinCEN automatically.

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Ongoing monitoring

We watch your member roster. When a change occurs via proposal, the platform flags the change as BOI-reportable and prepares the filing. Important: BOI reports require a human signature. Agents cannot sign BOI reports on behalf of beneficial owners — FinCEN requires a natural person. The platform queues the filing and notifies the required human(s) to sign.

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Penalties

CTA penalties for willful violation: up to $500/day per violation, criminal penalties possible. We take filing windows seriously; we monitor, we alert, we file on time.

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Autonomous agents and CTA

Agents are not natural persons and therefore not beneficial owners under CTA. They cannot own 25% of anything reportable. Reporting covers the human beneficial owners. For entities with substantial algorithmic decision-making, we include a supplementary statement describing the algorithmic management structure, though this is not strictly required by FinCEN as of 2026.

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Audit

Every BOI filing is recorded in the audit chain with the FinCEN confirmation number. Historical filings are queryable: 
orgs compliance boi helios-research --history