On February 27, 2025, FinCEN announced that it will not issue fines or penalties or take other enforcement actions for failure to file or update Beneficial Ownership Information (BOI) reports by the current deadlines of the Corporate Transparency Act (CTA). Additionally, FinCEN indicated that it will issue an interim final rule by March 21, 2025 that will once again extend the reporting deadlines and provide additional guidance.
Accordingly, while the BOI reporting requirements remain in effect, no penalties or enforcement actions will be taken for failure to file or update BOI reports until after new deadlines are set in the forthcoming interim final rule. This provides additional time for businesses to comply with BOI reporting requirements, and companies need not scramble now to submit BOI reports.
The landscape on this issue will continue evolving. In addition to ongoing litigation, legislative efforts are also underway to amend or repeal the BOI reporting requirements. On February 11, 2025, a bill that would extend the filing deadline to January 1, 2026 was passed by the U.S. House of Representatives and will move to the Senate.
We will continue to provide additional updates as information becomes available.