Update as of March 21, 2025
On March 21, 2025, FinCEN issued an interim final rule eliminating the requirement for U.S. companies and individuals to report Beneficial Ownership Information (BOI) under the Corporate Transparency Act. This follows the Treasury Department’s March 2, 2025, decision to suspend enforcement of BOI reporting for domestic entities. Under the new rule, only foreign entities registered to do business in the U.S. are considered reporting companies. As a result, domestic entities are no longer required to file BOI reports, and U.S. persons are exempt from related reporting obligations.
Foreign entities now subject to BOI reporting must submit their reports within 30 days if they were registered before March 21, 2025. Those registering afterward have 30 calendar days from receiving notice of their effective registration to file. FinCEN is accepting public comments on this interim rule and expects to finalize it later this year. This change aims to reduce compliance burdens on small businesses while maintaining transparency objectives.
Update as of March 2, 2025
On March 2, 2025, the Treasury Department announced that it has suspended enforcement of the BOI reporting rule under the Corporate Transparency Act for U.S. citizens and domestic reporting companies. No penalties or fines will be imposed under existing deadlines or after future rule changes take effect. Treasury has also proposed a revision to the rule to apply only to foreign reporting companies, aiming to reduce regulatory burdens on small businesses while maintaining its public interest goals.
Update as of February 28, 2025
The Financial Crimes Enforcement Network (FinCEN) has announced that it will not impose fines, penalties, or take enforcement actions against companies failing to file or update BOI reports by current deadlines. This policy will remain until a forthcoming interim final rule becomes effective and new due dates are established. FinCEN plans to issue this interim final rule by March 21, 2025, aiming to provide updated guidance and clarity. Additionally, FinCEN intends to seek public comments on potential revisions to existing BOI reporting requirements to minimize burdens on small businesses while ensuring the information remains valuable for national security and law enforcement purposes.
For more background on BOI reporting requirements and recent legal developments, read ARB’s previous coverage:
