Corporate Transparency Act update

Updates to the CTA/BOI reporting requirement

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that removes the requirement for U.S. Companies and U.S. persons to report Beneficial Ownership Information (BOI) to FinCEN under the Corporate Transparency Act.

The rule revises the definition of “reporting company” to mean only those entities that are formed under the law of a foreign country and have registered to do business in any U.S. State or Tribal jurisdiction by filing a document with a Secretary of State. Entities previously known as “domestic reporting companies” are also exempt from BOI reporting per the interim final rule.

• Foreign reporting companies registered to do business in the United States before March 21, 2025 must file BOI reports no later than April 20.
• Foreign reporting companies registered to do business in the United States after March 20, 2025 must file BOI reports within 30 days of their registration’s effective date.

Based on this newly released interim final rule, all entities created in the United States and their beneficial owners will be exempt from the requirement to report BOI to FinCEN. Foreign entities that meet the new definition of “reporting company” as outlined above and do not qualify for an exemption from reporting requirements must report their BOI to FinCEN under the following deadlines:

FinCEN is expected to finalize the rule this year. This is certainly great news for the majority of our clients! Please let us know if you have any questions or if we can help in any way.