FinCEN BOI Reporting, Enforcement

Updated on: Mar 2, 2025

Latest Event


  • Feb. 27, 2025 FinCEN Stay BOI Enforcements
  • On Feb. 27, 2025, FinCEN reported that the agency will not issue fines or penalties, or take any other enforcement actions in connection with BOI reporting deadlines.
  • No such actions taken until forthcoming interim final rule effective, due dates passed.
  • Intent to issue interim final rule extending BOI reporting deadlines by Mar. 21, 2025.
  • Also, noted intent to solicit public comment on potential revisions to existing BOI reporting requirements, with notice of proposal anticipated to be issued later this year.
  • Recognized need for new guidance, clarity quickly as possible, while ensuring reporting of BOI highly useful to important national security, intelligence, and law enforcement.

On Feb. 18, FinCEN extended BOI reporting deadline after court ruling.

  • FinCEN reported beneficial ownership information (BOI) reporting requirements under Corporate transparency act (31 USC 5336) are back in effect following court decision.
  • Follows Dec. 2024 preliminary injunction blocking reporting requirement, see #236025
  • Court Ruling
  • US District Court agreed to stay order blocking reporting until the appeal is completed.
  • Given decision, FinCEN’s regulations implementing BOI reporting requirements are no longer stayed, reporting is now mandatory, will provide additional time for reporting.
  • Deadline Extension
  • Recognizes that reporting companies may need additional time to comply with BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days.
  • For most companies, new deadline to file initial or corrected report is Mar. 21, 2025.
  • The reporting companies that were previously provided a reporting deadline later than the Mar. 21, 2025 deadline must file their initial BOI report by that later deadline.
  • FinCEN will provide update before then of any further modification, recognizing that reporting companies may need additional time to comply with BOI reporting obligation.
  • Isaac Winkles, companies owned by Isaac Winkles, the National Small Business Association and its members are not currently required to report BOI at this time.
  • Revisions To Reporting
  • In keeping with US Treasury commitment to reducing regulatory burden on businesses, during 30-day period will assess its options to further modify deadlines.
  • Also intends to initiate a process this year to revise the beneficial ownership information reporting rule to reduce burden for lower-risk entities, small businesses.
  • Feb. 27, 2025 FinCEN Stay BOI Enforcements
  • On Feb. 27, 2025, FinCEN reported that the agency will not issue fines or penalties, or take any other enforcement actions in connection with BOI reporting deadlines.
  • No such actions taken until forthcoming interim final rule effective, due dates passed.
  • Intent to issue interim final rule extending BOI reporting deadlines by Mar. 21, 2025.
  • Also, noted intent to solicit public comment on potential revisions to existing BOI reporting requirements, with notice of proposal anticipated to be issued later this year.
  • Recognized need for new guidance, clarity quickly as possible, while ensuring reporting of BOI highly useful to important national security, intelligence, and law enforcement.
Regulators
FinCEN
Entity Types
Bank; Corp; Ins
Reference
PR, 2/27/2025; Nt FIN-2025-CTA1, 2/18/2025; Citation: 31 USC 5336;
Functions
AML; Compliance; Financial; Legal; Operations; Record Retention; Registration/Licensing; Reporting; Sanctions; Treasury
Countries
United States of America
Category
State
N/A
Products
Banking; Corporate; Equity; Insurance
Rule Type
Final
Regions
Am
Rule Date
Feb 18, 2025
Effective Date
Mar 21, 2025
Rule ID
244300
Linked to
Reg. Last Update
Feb 27, 2025
Report Section
AML & Enforcement