On January 1, 2026, the New York LLC Transparency Act is scheduled to take effect, introducing new disclosure requirements for limited liability companies in New York State.

The legislation will have significant implications for all LLCs formed or registered to do business in New York. Furthermore, a proposed amendment awaiting the Governor’s signature would broadly require reporting by LLCs formed or registered in New York, similar to the type of broad beneficial ownership information reporting requirements that the Treasury Department required in rules implementing the federal Corporate Transparency Act, before the Treasury limited these to foreign entities and foreign beneficial owners in a March 2025 interim rule.

Click here to read Crowell’s recent client alert about the Act.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Photo of James M. Carolan James M. Carolan

Jim Carolan is a senior counsel in Crowell & Moring’s Corporate group, based in New York. Jim specializes in real estate transactions, offering extensive expertise in acquisitions, sales, leasing, and financing. His practice encompasses the acquisition and disposition of single assets and portfolios…

Jim Carolan is a senior counsel in Crowell & Moring’s Corporate group, based in New York. Jim specializes in real estate transactions, offering extensive expertise in acquisitions, sales, leasing, and financing. His practice encompasses the acquisition and disposition of single assets and portfolios, including in distressed situations, ground leases, space leases for office, retail, warehouse, and other uses, as well as asset-based and mezzanine financings and workouts. Jim also advises on development and investment joint ventures, construction and design arrangements, and complex easements for conservation, utilities, construction, and access.

Photo of Jackie Schaeffer Jackie Schaeffer

Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international

Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international trade, including economic sanctions, anti-money laundering (AML), export controls, and the Committee on Foreign Investment in the United States (CFIUS).

Jackie received her J.D. from Stanford Law School where she was a Franke Fellow in Global Business Law.  She received her LLM in EU and International Business Law from The University of Vienna School of Law. During law school, she worked at the Estonian Foreign Ministry, clerked for the Honorable Chief Justice of the Supreme Court of the Republic of Rwanda, and worked with the United Nations Independent Commission of Inquiry on Ukraine.

Prior to law school, Jackie was a Coro Fellow in Public Affairs in San Francisco.