In March 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for U.S. companies to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act.

With this rule, domestic entities created in the U.S., as well as their beneficial owners, are currently exempt from the requirement to file initial BOI reports or to update or correct previously filed reports. The reporting requirement didn’t disappear for everyone. Existing foreign companies that were required to report under the previous rule were given an additional 30 days to comply (that deadline has now passed). 

Written comments were being accepted on the interim final rule until May 27, 2025. But, even then, as Forbes’ Kelly Erb points out, “Despite Treasury’s assertions, the executive branch cannot simply overturn laws passed by Congress. It can, however, choose not to aggressively enforce a law (as we have seen in other contexts, like the criminalization of cannabis).”

The U.S Treasury Department has vowed to do just that, stating that “not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either.” 

Reactions are mixed from the business community. Of course, no legitimate small business owner is in favor of money laundering access, but many groups questioned whether BOI would adequately fill in those loopholes to make it worth the administrative burden it presented. 

That being said, whatever work you did to prepare for BOI—whether you had already filed or not—will likely not be in vain. The measure was a decades-long bipartisan effort that is likely to resurface in due time, just as other rulings covering issues such as overtime pay and independent contractor definitions tend to be reissued with every new administration. 

Keep an eye on changes posted by FinCEN, including this helpful FAQ page, and heed the advice of your legal and financial advisors in the meantime. Feel free to contact us with questions. 

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