CTA Compliance Update – Foreign Reporting Companies Only

BOIR No Longer Required for Domestic Companies

There is a significant development regarding Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA).

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that removes the Beneficial Ownership Information (BOI) reporting requirement for domestic reporting companies. This rule is effective immediately.

Under the Corporate Transparency Act, domestic reporting companies include corporations, limited liability companies (LLCs), and other entities created by the filing of a document with a secretary of state or similar office under the laws of a U.S. state or tribal jurisdiction. These entities are no longer required to file BOI reports.

The reporting requirement now applies only to foreign reporting companies. Foreign reporting companies are entities formed under the laws of a foreign country that are registered to do business in the United States by filing with a secretary of state or similar office. These foreign entities may still be required to file BOI reports unless they qualify for an exemption.

If You’ve Already Filed: If your U.S. entity has already submitted a BOI report, you are not required to amend or withdraw it. FinCEN has stated that no further action is needed in connection with previously submitted filings.

If You Haven’t Filed Yet: If your U.S. entity has not filed a BOI report, you are no longer required to do so. The interim final rule removes the filing obligation for domestic entities going forward.