** REVISED BOI ENFORCEMENT **

 

As of March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule that significantly changes beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act:

  • The rule removes the BOI reporting requirement for all U.S.-created companies (formerly “domestic reporting companies”).  
  • Only foreign companies registered to do business in the U.S. (now the sole “reporting companies”) are required to report BOI.
  • These foreign entities are not required to report U.S. persons as beneficial owners, and U.S. persons are not required to report BOI related to these foreign entities.

 

Deadlines for Foreign Entities to file BOI Reports

  • Registered before interim final rule: 30 days from publication date to file
  • Registered after interim final rule: 30 days from registration to file

 

Questions?

CLH clients may contact their account manager with any questions regarding BOI.

 

Historical BOI Reporting Information

Previously-reported information on BOI requirements is available here.