CTA/BOI Update: FinCEN Pauses Enforcement of CTA/BOI Reporting Deadlines Until Further Notice

Our firm is providing this communication to give you an update of the latest regulatory development from FinCEN regarding the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). 

Overview of Latest Development

In keeping with Department of Treasury’s communicated commitment to reduce regulatory burden on businesses, FinCEN announced on Thursday, February 27, 2025, that it will pause enforcement actions and not issue fines or penalties against companies for failing to file or update beneficial ownership information reports pursuant to previously promulgated CTA reporting deadlines. Please refer to the FinCEN announcement at: FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines | FinCEN.gov.

Given the recent legal and legislative developments, and related confusion and uncertainty surrounding CTA/BOI reporting, FinCEN’s announcement pausing reporting deadline enforcement is welcome relief for reporting companies.

FinCEN noted its intent to issue an interim final rule by March 21, 2025, with updated guidance on extending BOI reporting deadlines. In addition, FinCEN stated it plans to seek public comment on potential revisions to existing BOI reporting requirements and will consider those comments as part of a notice of proposed rulemaking to be issued later this year to determine whether modifications to the reporting deadlines are warranted.

The treasury department said in a statement that it also would embark on a rulemaking that narrowed the scope of the beneficial ownership information reporting rule under the law to “foreign reporting companies only.”

Next Steps

We encourage you to stay informed. For additional information regarding the CTA’s beneficial ownership reporting requirements, please refer to FinCEN’s guidance at: Beneficial Ownership Information Reporting | FinCEN.gov.

As always, please feel free to contact us if you have any questions.