Recent News & Blog / BOI injunction lifted: FinCEN updates requirements for US companies
March 27, 2025
Important Update:
On March 21, 2025, FinCEN issued an interim final rule removing the new BOI reporting requirements for U.S. companies and U.S. persons. Now, the newly implemented BOI reporting requirements will only apply to those entities that are formed in another country. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN within 30 days. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.
For more information and answers to common questions about the new interim final rule, click here.
Previous February 28, 2025 Update:
On February 28, 2025, FinCEN announced an extension of the March 21, 2025 BOI reporting deadline and has temporarily suspended enforcement. No fines or penalties will be issued for failure to file or update BOI reports until a new interim final rule takes effect, which will establish revised due dates. The agency also plans to revise BOI reporting requirements to reduce regulatory burden. A new deadline will be announced by March 21, so businesses should stay tuned for further guidance from FinCEN.
Previous February 16, 2025 Update:
The ongoing developments surrounding the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements took another turn on February 16, 2025. A federal judge lifted the preliminary injunction that had temporarily halted the enforcement of the BOI reporting requirements. In response, the Financial Crimes Enforcement Network (FinCEN) announced a 30-day delay in filing deadlines for affected entities.
What This Means for Businesses
With the injunction lifted, FinCEN’s BOI reporting requirements remain in effect, and impacted entities will have an additional 30 days to submit their reports. FinCEN has clarified the new filing deadlines:
- Most reporting companies must file an initial, updated, and/or corrected BOI report by March 21, 2025.
- Companies formed or registered on or after February 18, 2025 must file within 30 days of creation or registration.
- Entities previously granted extensions due to disaster relief should follow the later deadlines.
Next Steps
- Determine Your Filing Obligation – Businesses affected by the injunction should confirm their new filing deadline based on FinCEN’s updated guidance.
- Monitor FinCEN Announcements – Additional guidance may be released to clarify deadlines and filing expectations. We encourage you to visit the BOI website for the latest news. We will update this article with any major developments.
- Ensure Compliance – Businesses should prepare to submit their BOI reports as soon as possible to avoid potential penalties. You can file using the BOI E-Filing System at any time.
Sources: FinCEN, Journal of Accountancy, and Wolters Kluwer
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