On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”).
Consistent with the U.S. Treasury Department’s announcement earlier this month, the new rule removes BOI reporting requirements for all U.S. reporting companies and their beneficial owners. U.S. persons who are beneficial owners of foreign reporting companies are also exempt from CTA reporting obligations under the new rule. Going forward, only companies formed under foreign law and that are registered to do business in the U.S. will be required to submit BOI reports.
The interim final rule extends the deadline for foreign reporting companies to file BOI reports to 30 days after the date the interim final rule is published in the Federal Register or 30 days after the foreign reporting company registers to do business in the U.S., whichever is later.
FinCEN will accept comments on the interim final rule for 60 days and intends to finalize the rule later this year.
While the interim final rule may be subject to future legal challenges, domestic companies and U.S. individuals are now relieved of reporting obligations under the CTA. KMK will continue to monitor any further developments and provide updates as they occur.
KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.
ADVERTISING MATERIAL.
© 2025 Keating Muething & Klekamp PLL. All Rights Reserved
- Partner
As a partner in the firm’s Business Representation & Transactions Group, Allie Westfall’s insight and proven analytical skills help translate the complexities of the often-challenging securities laws. Allie’s counsel ...
- Associate
Chris Colloton is an associate in the firm's Business Representation & Transactions Group, focusing his practice in the areas of securities, mergers and acquisitions, and business planning.
Chris earned his law degree from the ...
Topics/Tags
Select- Corporate Transparency Act
- SEC
- Securities Law
- Nasdaq
- Securities Regulation
- Cybersecurity and Privacy Law
- EDGAR
- EDGAR Next
- Corporate Law
- IRS
- Cybersecurity Regulation
- Tax Planning
- Coronavirus
- Clawback Rules
- SEC Enforcement
- Taxation
- Dodd-Frank
- Mergers & Acquisitions
- Paycheck Protection Program
- JOBS Act
- Corporate Tax
- Corporate Governance
- FAST Act
- Economic Sanctions
- Ohio LLC Act
- Consumer Protection Act
- Proxy Access Rules
- Securities Litigation
- Crowdfunding
- Conflict Minerals
- Cryptocurrency
- Hedging
- Real Estate Law
- Emerging Growth Companies
- Investors
- Pay Ratio Disclosure
- Whistleblower
- Private Offerings
- Intellectual Property
- Technology
- Opportunity Zone
- LIBOR
- Executive Compensation
- Health Care Act
- Accredited Investors
- Sales Tax
- United States Supreme Court
- Online Trading Platforms
- Wall Street Reform
- IPO
- Registration Statement
- Annual Reports
- Family-Controlled Entities
- Gift and Estate Transfers
- Ohio Foreclosure Reform
- Director Compensation
- Board of Directors
- Director Independence
- Total Shareholder Return
- Cyber Insurance
- Data Breach
- Lenders
- Receivership Statute
- Regulation A
- Regulation D
- CDEs
- CDFI Fund
- Community Development Entities
- Community Development Financial Institutions Fund
- Compensation Committee Certification
- Government Shutdown
- New Markets Tax Credit
- NMTC
- NMTC Financing
- Regulation Fair Disclosure
- Social Media
- Benefits
- Healthcare Reform
- Litigation
- Marketing
- Public Company Transition Rules
- Employment Incentives
- HIRE Act
- Social Security Tax
- Tax Credit
Recent Posts
- Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons
- Corporate Transparency Act Update: FinCEN Will Not Enforce the CTA Until Interim Rule is Effective
- Corporate Transparency Act Update: Injunction Lifted - Corporate Transparency Act Back in Effect
- Corporate Transparency Act Update: FinCEN Says Reporting Obligations Remain On Hold
- Next Up in 2025: EDGAR Next
- Corporate Transparency Act Update: Supreme Court Stays Nationwide Injunction – CTA Reporting Obligations Back in Effect
- Corporate Transparency Act Updates: Fifth Circuit Vacates the Stay and Preliminary Injunction Reinstated
- Corporate Transparency Act Reporting Deadline Back in Effect; FinCEN Grants Deadline Extension
- Fifth Circuit Nixes Nasdaq Board Diversity Rules
- Corporate Transparency Act Update: Texas Federal Court Issues Nationwide Injunction