Background
The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their way through the courts, reporting requirements have been suspended and reinstated on multiple occasions. In the latest turn of events, on Sunday, March 2, 2025, the U.S. Department of the Treasury (Treasury Department) issued a notice indicating that it will not enforce any penalties or fines associated with the BOI reporting rule against U.S. citizens or domestic reporting companies or their beneficial owners, with respect to existing and future deadlines.
On February 27, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a statement announcing that no later than March 21, 2025, it plans to issue an interim final rule that extends BOI reporting deadlines. Subsequent to FinCEN’s announcement, the Treasury Department indicated that the rulemaking will narrow the scope of the rule to foreign reporting companies only.
As of now, no CTA reports are required to be filed until on or after March 21, 2025. Beyond that, it is not clear at this point what is next for the CTA, and there could be additional changes coming.
Visit FinCEN.gov/boi for the latest updates on Beneficial Ownership Information reporting.
For more information on this topic, please read our prior Client Alert here.
DISCLAIMER: This Client Alert is for informational purposes only. Any legal advice regarding reporting obligations or application of the CTA to any client will require a new engagement with DRM. If your company is an existing client of the firm and has questions about the application of the CTA, please note that the firm’s current engagement does not include legal advice regarding your company’s reporting obligations or compliance with the CTA.
