No, a company that completely dissolved before January 1, 2024, doesn’t need to report its
beneficial ownership information to FinCEN. The reporting requirement only applies to companies that
were still legal entities on or after that date.
Here’s a breakdown:
• Dissolved Before January 1, 2024: A company is not required to report its beneficial
ownership information to FinCEN if it ceased to exist as a legal entity before January 1, 2024,
meaning that it entirely completed the process of formally and irrevocably dissolving.
• Dissolved After January 1, 2024: If a reporting company continued to exist as a legal entity
for any period of time on or after January 1, 2024 (i.e., did not entirely complete the process of
formally and irrevocably dissolving before January 1, 2024), then it is required to report its
beneficial ownership information to FinCEN, even if the company had wound up its affairs and ceased
conducting business before January 1, 2024.
• Created After January 1, 2024: If a reporting company was created or registered on or after
January 1, 2024, and subsequently ceased to exist, then it is required to report its beneficial
ownership information to FinCEN—even if it ceased to exist before its initial beneficial ownership
information report was due.