Corporate Transparency Act and Beneficial Ownership Information (“BOI”) Reporting (Update – April 2025)

FinCEN Removes BOI Reporting Requirements for U.S. Companies.

After much scrutiny, legal challenges, and delays, the original reporting requirements under Beneficial Ownership Information (“BOI”) have been permanently changed. On March 26, 2025., the Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule in the Federal Register that revises the reporting requirements for some companies and includes an extension of the time to report for companies still subject to the Corporate Transparency Act (“CTA”).

Notably, the biggest change to the BOI is that US companies and US persons, are exempt from BOI reporting. By removing this, much of the uproar over the collection of sensitive financial information of small business owners seems to have quieted some of the critics. It is possible more changes are to come for the CTA and BOI, but for now, the issue seems to be settled.