UPDATE – BOI Reporting Update: U.S. companies and U.S. persons no longer required to comply

The Financial Crimes Enforcement Network (FinCEN) has removed the requirement that U.S. companies and U.S. persons must report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. This interim final rule is consistent with the Treasury Department’s recent announcement that it was suspending enforcement of the CTA against U.S. citizens, domestic reporting companies, and their beneficial owners, and that it would be narrowing the scope of the BOI reporting rule so that it applies only to foreign reporting companies.

Under the revised rules, all entities created in the United States (including those previously called “domestic reporting companies”) and their beneficial owners are exempt from the BOI reporting requirement, including the requirement to update or correct BOI previously reported to FinCEN. Foreign entities that meet the new definition of “reporting company” and do not qualify for a reporting exemption must report their BOI to FinCEN, but are not required to report any U.S. persons as beneficial owners. U.S. persons are not required to report BOI with respect to any such foreign entity for which they are a beneficial owner.

Reporting Deadlines for Foreign Companies

BOI reporting by foreign reporting companies is still required, and foreign entities that are registered to do business in the United States before the publication date of the interim final rule must file BOI reports no later than 30 days from that date.

Foreign entities that are registered to do business in the United States on or after the publication date of the interim final rule have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

How to File

If you determine that your entity is required to file, filing a BOI report with FinCEN is done through the FinCEN’s BOI E-Filing System.

Additional information and assistance

For additional information related to BOI reporting, as well as a listing of FinCEN FAQs, you may visit their website here,

While our firm is not able to assist in the preparation and submission of BOI reports, we are here to help address related compliance and business questions. Contact our team to discuss how we can support your entity’s broader accounting and advisory needs.