"Beneficial Ownership Information" Requirement

The Corporate Transparency Act (CTA)

Does your entity still need to comply with the BOI reporting requirement with the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN)?

Most likely, the answer has changed for many entities.

As of March 26, 2025, a significant update to the BOI Reporting Rule has taken effect under the Corporate Transparency Act. The U.S. Treasury’s FinCEN has issued a new interim final rule that exempts all entities created in the United States—including those previously known as "domestic reporting companies"—and their beneficial owners from the requirement to submit BOI reports.

Under this updated rule, only foreign entities that are registered to do business in the U.S. (formerly known as "foreign reporting companies") must file BOI reports. These foreign entities are not required to report any U.S. persons who are beneficial owners, and likewise, U.S. persons are not required to report BOI related to these foreign entities.

For foreign reporting companies, new deadlines apply:

• Entities registered to do business in the U.S. before March 26, 2025, must file their initial BOI reports by April 25, 2025.

• Entities registering after that date have 30 calendar days after effective registration to file their reports.

Failure to comply with BOI reporting requirements may carry penalties, but with the updated rule, FinCEN will not enforce penalties or fines against domestic entities or their beneficial owners, reflecting this important regulatory change.

This update reduces the compliance burden for most U.S.-based businesses while maintaining transparency obligations for certain foreign-registered entities.

Make sure to review your entity’s status to determine if you are subject to the BOI reporting requirements and adjust your filings accordingly. For more information see here.

Contact Samira Amato's law office for assistance with meeting the BOI reporting deadline.

✅ Got questions? Contact our office at 408-295-6740.

Law Offices of Samira Amato - www.samiralaw.com