02/24/2025
FYI on FINCEN
FinCEN Sets March 21 BOI Reporting Deadline
Most companies have until March 21 to file required beneficial ownership information (BOI) reports with the Financial Crimes Enforcement Network (FinCEN) under new guidance issued by the agency. While a Texas federal judge’s order temporarily barred FinCEN from penalizing entities that did not file required BOI reports, that judge issued a new order Tuesday allowing the agency to enforce the reporting requirements under the Corporate Transparency Act (CTA).
To give entities time to comply with their BOI reporting obligations, the Treasury Department generally extended the filing deadline to 30 days from Feb. 19 for most companies. Additionally, as part of Treasury’s commitment to reducing the regulatory burden on businesses, FinCEN will continue assessing its options for further modifying the deadline during the 30-day period while continuing to prioritize reporting by entities that pose the most serious national security risks. FinCEN also plans to revise its BOI reporting rules to reduce the burden for lower-risk entities, including many U.S. small businesses, later this year.
The March 21 reporting deadline will apply to most reporting companies, but those entities previously given deadlines after that date should use the later deadline. For example, a business that qualified for disaster relief extension and was given an April deadline would not be required to file by the March deadline. Several court challenges to the CTA are currently being litigated, which could impact FinCEN’s enforcement of BOI filing requirements.
The reporting deadline could also be postponed beyond March 21 by bipartisan legislation (H.R. 736) to postpone BOI reporting until Jan. 1, 2026. The bill passed the U.S. House of Representatives Feb. 10 and has been referred to the Senate where it has not come up for a vote. We are closely monitoring the situation and will keep you updated as to any additional changes.