On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that significantly changes the scope of BOI reporting obligations. According to FinCEN’s official press release, U.S. companies and U.S. persons are no longer required to report beneficial ownership information.
The revised rule redefines a "reporting company" to include only entities formed under the laws of a foreign country that are registered to do business in a U.S. state or Tribal jurisdiction. As a result, entities previously classified as “domestic reporting companies” are now exempt from BOI reporting requirements.
Key Deadlines for Foreign Reporting Companies:
- Foreign entities registered to do business in the U.S. before the interim final rule’s publication date must file their BOI reports within 30 days of that date.
- Foreign entities registering to do business in the U.S. on or after the publication date must file their initial BOI report within 30 calendar days of receiving confirmation that their registration is effective.
FinCEN anticipates finalizing this rule later in 2025. We will continue to monitor developments and provide timely updates as new guidance is released.
