On March 26, 2025, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) published an interim final rule to narrow the existing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) to require only entities previously defined as “foreign reporting companies” to report BOI. Under this interim final rule, entities previously defined as “domestic reporting companies” are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN. With limited exceptions, the interim final rule does not change the existing requirement for foreign reporting companies to file BOI reports, but it extends the deadline to file initial BOI reports, and to update or correct previously filed BOI reports, to April 25, 2025 to give foreign reporting companies additional time to comply.

The rule is effective immediately, and a final rule is expected later this year. The rule can be found here, and a press release regarding the rule can be found here. The deadline to submit comments on the rule is May 27, 2025.

We have a team of attorneys who are prepared to assist with any questions you may have regarding the CTA. If you have questions, please contact a member of our team.