There has been an important update regarding Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act. In line with the Treasury Department’s March 2, 2025, announcement, the Financial Crimes Enforcement Network (FinCEN) has published an interim final rule that does away with requirements for U.S. companies and U.S. persons to report BOI.
As part of this interim final rule, FinCEN modified its definition of “reporting company” to include only organizations formed outside the United States that have registered to operate in any U.S. State or Tribal jurisdiction by filing documents with the relevant secretary of state or a comparable office —previously referred to as “foreign reporting companies.”
The rule also exempts any company that was once classified as a “domestic reporting company” from submitting BOI.
Under these new provisions, all businesses created within the United States — including former “domestic reporting companies” — are no longer obligated to provide BOI to FinCEN. Meanwhile, entities that fit the updated definition of “reporting company” and are not otherwise exempt must disclose their BOI according to new deadlines. These foreign entities are not required to designate any U.S. individuals as beneficial owners, and U.S. persons similarly are not obliged to furnish BOI regarding foreign entities they own.
If you would like further information about the CTA or need assistance in complying with the law, please contact us.
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