Key Takeaways:
- FinCEN has removed BOI reporting requirements for U.S. companies under the Corporate Transparency Act, ending the need to file ownership details.
- Foreign entities registered to do business in the U.S. must still file BOI reports within 30 days of the new rule’s effective date; a U.S. person who is a beneficial owner of a reporting company is exempt and not required to provide any information.
- Previous BOI filing deadlines and extensions for U.S. companies are no longer relevant due to the new FinCEN rule.
—
On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule eliminating the beneficial ownership information (BOI) reporting requirement for U.S. companies and U.S. persons under the Corporate Transparency Act (CTA). This new rule supersedes prior guidance and enforcement timelines, including the 30-day filing extension discussed below.
It is important to note that foreign entities registered to do business in the United States remain subject to BOI reporting requirements. These entities must file within 30 days of the interim final rule’s effective date unless further guidance is issued.
U.S. Person Exemption: On any required beneficial ownership interest report, a company reports only non-U.S. beneficial owners. A U.S. person who is a beneficial owner of a reporting company is exempt from the CTA and is not required to provide any information.
We encourage all organizations to review the full FinCEN release and reach out to your legal counsel for advice specific to your situation as we are not able to provide legal guidance on this matter.