Just to respond to the question above, CTA does not apply to entities with greater than $5 million in gross receipts, 20 full-time employees and which have a physical office in the US.  Presumably, collusion with 20 or more is not a thing and I guess the landlords are on the hook next.  So we're not really talking about very large entities (or those with a significant amount of assets or funds flow).

On the assumption that these small entities are conducting some form of money laundering or criminal activity that is being funded with (or incentivized by) US currency or crypto, then that currency (whether in paper or electronic form) goes through the US banking system (or fintech equivalent system).  So it seems to me that the end points of the US banking/fintech system are where the risk lies (i.e., the weak link), not from corporate ownership or control of those assets (though that may be helpful information).  That is, ownership of a financial account should be ascertained at the outset, and transaction activity 'could be' effectively reviewed and monitored.  Yes, you could incentivize an evil doer with shares of stock or a profits interest (i.e., something that would never hit the US banking system currently), but eventually, the assets owned by that entity would end up in (or are already in) the US banking system.  If those assets were "non-productive" and not reported (due to the exception above), it's unlikely they would be unproductive or go unreported for long.

On the other hand, if we are concerned about hard currency moving through the 'black market' then no CTA system is going to help you, period.  You would be better off setting up DieBold machines at the banks (or endpoints) to scan and electronically track all US currency as it moves through the system.  The serial number on a dollar bill seems to be the one number in our financial system that isn't subject to being hacked, no one pays attention to, and yet, there it is.  I simply think we are going to spend inordinate amounts of effort tracking bad information on who owns the suitcase that the money was once held in.  And in many states, the "unique identifier" for BOI (the owner of the suitcase) will be less than conclusive to begin with (i.e., garbage in, garbage out).