This year’s National Defense Authorization Act (NDAA), which passed over President Trump’s veto on New Year’s Day, requires the US Department of the Treasury to establish a registry of the individual beneficial owners of potentially millions of “reporting companies.” The measure is intended to target the so-called “shell corporations” that US authorities believe are used by criminals to conceal money laundering, fraud, corruption, and other types of misconduct. Under the law, a “reporting company” will be required to disclose the identity of any individual who: (1) owns or controls 25% or more of its ownership interests; or (2) exercises “substantial control” over the company. We explore these provisions, and other aspects of the NDAA’s anti-money laundering provisions, in our full client briefing.