Corporate Transparency Act Update

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule exempting U.S. companies and U.S. persons from the requirement to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). This revision narrows the definition of “reporting company” to include only entities formed under foreign laws that have registered to do business in the U.S.

The U.S. Department of the Treasury announced that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies and their beneficial owners under the current or forthcoming CTA reporting requirements.

Foreign entities registered to do business in the U.S. are now required to file their initial BOI reports within 30 days of receiving notice that their registration is effective. For those registered before the interim final rule’s publication, the deadline to file is 30 days from that publication date.

Further revisions to the CTA and its implementation are possible, pending legal outcomes and legislative actions.