After several months of updates and clarifications, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule on March 21, 2025, that significantly narrows the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act.

Key highlights from this update include:

• U.S. companies and U.S. individuals are no longer required to file BOI reports.
• Only foreign entities that are registered to do business in a U.S. state or tribal jurisdiction are now considered “reporting companies.”
• Foreign reporting companies no longer need to report U.S. persons as beneficial owners.
• U.S. persons are no longer required to provide their BOI to foreign reporting companies.
• Foreign entities registered before March 21, 2025, have been granted a 30-day extension to file their initial BOI reports.

We hope this update will ease the compliance burden for many of our clients. We recommend reviewing these changes to determine how they may apply to your specific situation.

Please note that this rule is still interim. FinCEN is accepting public comments for 60 days and expects to issue a final rule later this year. To stay informed or submit comments, visit FinCEN’s BOI reporting page here: https://fincen.gov/boi.