NEWS: Yesterday, a federal judge in Texas lifted an order that blocked the enforcement of a federal anti-money laundering law that requires business entities to disclose the identities of their real beneficial owners to the U.S. Treasury Department.
This means that the on-again-off-again beneficial ownership information (BOI) reporting requirements under the federal Corporate Transparency Act (CTA) are once again back in effect.
For an explanation of the BOI rules and their significance to credit unions, please see this Compliance Courier.
Because reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
In addition, FinCEN said that it plans to revise the rule, potentially reducing its impact on some businesses:
Notably, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.
Updated Deadlines
- For the vast majority of reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.
- Reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
Due to other litigation, members of National Small Business Association (as of March 1, 2024) are not required to report their beneficial ownership information to FinCEN for now.
Reporting companies can report their beneficial ownership information directly to FinCEN, free of charge, using FinCEN’s E-Filing system. More information is available here.