UPDATE: FinCEN Removes Corporate Transparency Act's Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Individuals; Sets New Deadlines for Foreign Companies

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) published an Interim Final Rule (“IFR”) removing the requirement for U.S. companies and U.S. individuals to report Beneficial Ownership Information (“BOI”) to FinCEN under the Corporate Transparency Act.

Chiefly, FinCEN updated the definition of “Reporting Company” to refer to only those entities that are formed under foreign law and have registered to do business in the U.S. All entities created in the U.S and their beneficial owners will be exempt from BOI reporting. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption must report their BOI to FinCEN under the following new deadlines. Reporting companies registered to do business in the U.S. before the date of publication of the IFR, March 21, 2025, must file BOI reports no later than 30 days from that date: Sunday, April 20, 2025. Reporting companies registered to do business in the U.S. on or after the date of publication of the IFR have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

We here at Wilk Auslander continually stay abreast of new developments and their applications in corporate law. If you would like to further discuss the CTA, please reach out to Stephen Albert at (212) 981-2320, salbert@wilkauslander.com, Jonathan Bender at (212) 981-2322, jbender@wilkauslander.com, Mark Clyman at (212) 981-2318, mclyman@wilkauslander.com, Jack Wilk at (212) 981-2333, jwilk@wilkauslander.com or Caitlyn Ford at (212) 981-2307, cford@wilkauslander.com.

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