As of March 21, 2024, the Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule regarding the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA).
The definition of “reporting companies”—companies required to file BOI reports with FinCEN under the CTA—has been significantly narrowed under the newly issued rule. It now only includes those companies formed under the law of a foreign country that are registered to conduct business in any state in the United States or Tribal jurisdiction through a filing with the secretary of state or similar office. Further, these reporting companies are no longer obligated to report U.S. persons as beneficial owners in their BOI report filings.
The updated filing deadline for the newly defined reporting companies (already in existence as of March 21, 2025) to file their BOI reports is Sunday, April 20, 2025. For foreign companies registered later, a BOI report must be filed within 30 days after receiving notice that the company’s registration is effective.
This interim rule is effective immediately; however, FinCEN has implemented a 60-day public comment period and expects to issue a final rule by the end of 2025. We will continue to monitor these rule changes and provide updates as they evolve.
