C&Mc Update on FinCEN BOI Reporting April 22, 2025

US Companies and US Persons are no longer subject to FinCEN Beneficial Ownership Reporting Requirements

On March 21, 2025, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the beneficial ownership information (BOI) reporting requirement under the Corporate Transparency Act for U.S. companies and U.S. persons.

Under the interim final rule, the definition of “reporting company” was revised to require only those entities formed under laws of a foreign country and registered in any U.S. State or Tribal jurisdiction to make the reports. These foreign entities will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.

All entities created under the laws of the United States and their beneficial owners will now be exempt from reporting requirements.

FinCEN is accepting comments on this interim final rule and intends to finalize the rule this year.