On March 2, 2025, the U.S. Treasury Department released a press release stating that:
- It will not enforce any penalties or fines against any company associated with the current March 21 beneficial owner information ("BOI") reporting deadline;
- It will not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners once the Financial Crimes Enforcement Network ("FinCEN")’s forthcoming interim final BOI rule changes (which FinCEN is expected to provide by March 21) take effect; and
- It will be issuing a proposed rulemaking that will narrow the scope of the BOI reporting rule to foreign reporting companies only.
Clients who are non-U.S. citizens and/or foreign reporting companies should still be prepared to make their BOI filings by the applicable deadline once FinCEN’s interim final rule and the Treasury Department’s future proposed rulemaking go into effect.
All of this may be subject to change in the event that the Treasury Department’s rulemaking is challenged as an invalid attempt to overrule an act of Congress.
Our Business & Corporate Law team will continue to monitor and provide updates on the Corporate Transparency Act’s legal developments. Please reach out to your attorney at Best & Flanagan with any questions about the CTA, or if there is any other assistance we can provide.