The Financial Crimes Enforcement Network (FinCEN) has announced that beneficial ownership information (BOI) reporting requirements are once again in effect. This follows a federal court’s decision to lift the remaining nationwide injunction against the Corporate Transparency Act (CTA) and the BOI reporting rule.
What This Means for Businesses
For most affected businesses, the new deadline to comply with BOI reporting requirements is now March 21, 2025. However, FinCEN has indicated that it is assessing potential modifications to deadlines and plans to provide further updates before the current deadline.
Key Considerations for Businesses
- The CTA requires certain U.S. and foreign entities to disclose their beneficial owners to FinCEN to prevent financial crimes such as money laundering and fraud.
- Companies formed before January 1, 2024, must report by March 21, 2025.
- Companies formed on or after January 1, 2024, have 90 days from formation to comply.
- Failure to report could result in significant penalties, including fines.
No New Obligations for Banks and Large Operating Companies
Importantly, these reporting changes do not create any new obligations for banks and other exempt entities including large operating companies. Financial institutions are still expected to conduct due diligence under existing anti-money laundering (AML) regulations but are not responsible for submitting BOI reports on behalf of their customers.
