The January 2021 passage of the Corporate Transparency Act paved the way for the United States’ first beneficial ownership registry. But the road has been rocky in the two-and-a-half years since, including an admission by the overarching agency last year that funding and staffing shortages were delaying further progress. With fewer than six months left before the widely anticipated registry’s debut and the start of mandatory reporting requirements for select new businesses, attorneys and others in the anti-money laundering space are watching, waiting and wondering if there are more hazards ahead. This article contains insights from attorneys Luciano Racco at Foley Hoag and Alan Granwell at Holland & Knight. See “Progress and Challenges in Implementation of Anti-Money Laundering Act of 2020” (Jun. 21, 2023).