March 2025 – BOI REPORTING UPDATE

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FinCEN Revises BOI Reporting Requirements for U.S. Companies

 

OVERVIEW

 

We are reaching out with another update of the latest developments regarding the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA).

 

On March 21st, the Financial Crimes Enforcement Network (FinCEN) addressed the BOI reporting burden on domestic companies and issued an interim ruling by announcing the following:

 

·     The BOI reporting requirement has been removed for U.S. companies and U.S. individuals.

·     Under this interim final rule, entities previously defined as “domestic reporting companies” are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN.

·     Currently, only foreign entities that have registered to do business in any U.S. State or Tribal jurisdiction have a BOI filing requirement.

 

NEXT STEPS

 

·     Impact on Previously Filed Reports – Companies that have already submitted BOI reports do not need to take further action.

·     Foreign Companies Still Required to File – The change does not affect foreign entities that are registered to do business in the U.S.—these entities still have a BOI reporting requirement.

 

If you have any questions regarding this development and you believe you still have a BOI filing requirement based on the revised BOI guidance once it is fully released, we strongly encourage you to consult with your legal counsel for guidance as soon as possible.