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United States – Reinstated Deadlines for Beneficial Ownership Reporting
In a crucial development for businesses in the United States (US), the Beneficial Ownership Information (BOI) filing requirement has been reinstated following a court decision. The Financial Crimes Enforcement Network (FinCEN) has set a new compliance deadline of the 21st of March 2025.
Key Updates
1. Temporary Injunction Lifted: On February 18th 2025, the U.S. District Court for the Eastern District of Texas issued a ruling that lifted the previously imposed nationwide injunction in the case of Texas Top Cop Shop, Inc., et al. v. US Department of Treasury, et al.
2. CTA Enforcement Resumed: As a result of this court decision, the Corporate Transparency Act (CTA) is now enforceable again. All reporting companies are required to submit their Beneficial Ownership Information (BOI) reports by the newly established deadline.
3. Extended Deadline: In response to the court’s decision, FinCEN has extended the filing deadline to March 21st, 2025, for most reporting companies.
What This Means for US Businesses
- BOI reporting requirements are now mandatory.
- Non-compliance may result in penalties.
- Companies that haven’t filed BOI reports must do so by March 21st, 2025.
FinCEN’s Response
Following the court decision, FinCEN has:
- Confirmed that BOI reporting requirements are enforceable.
- Extended the filing deadline to accommodate companies needing additional time to comply.
Required Actions
If your company has not yet filed its BOI report:
1. Review your reporting obligations under the CTA.
2. Gather necessary beneficial ownership information.
3. Prepare and submit your BOI report before the March 21st, 2025 deadline.
Note: Companies that have already completed their BOI filings are not required to take further action at this time, unless there have been changes to their beneficial ownership structure.
For assistance with BOI filing, contact our expert team at mercator@citco.com.
Read our Key Insights and FAQs on the US Corporate Transparency Act.
