LATEST UPDATE on the Corporate Transparency Act and BOI Report Filings

On February 27, 2025, FinCEN issued an immediate press release stating it would not impose fines, penalties, or take any other enforcement actions against companies that fail to file or update Beneficial Ownership Information ("BOI") reports pursuant to the Corporate Transparency Act ("CTA") by the current deadlines. FinCEN also announced that it would be revising BOI reporting deadlines through an interim final rule set to be issued no later than March 21, 2025.

Following FinCEN’s announcement, the Treasury Department released a statement on March 2, 2025, confirming that it will not enforce any penalties or fines related to the BOI reporting rule under the existing deadlines. Moreover, once the forthcoming rule changes take effect, the Treasury Department has indicated that U.S. citizens, domestic reporting companies, and their beneficial owners will not be subject to enforcement actions for prior noncompliance. The agency also revealed plans to issue a proposed rulemaking that would narrow the rule’s applicability to foreign reporting companies only.

For those domestic reporting companies that have already filed BOI reports, note that any continuing obligations to file updated BOI reports will seemingly terminate pursuant to the interim final rule that is expected before March 21, 2025. However, the BOI filings remain voluntary at this point, and if any reporting companies desire to comply with the CTA and avoid any non-compliance or confusion that may occur if the CTA is ever reinforced after the interim final rule takes effect, those reporting companies may still file a BOI report. 

For further inquiries or questions, please contact Attorney Frank J. Portera at fportera@lavellelaw.com or (847) 705-7555.