- There have been no changes to the CTA’s reporting requirements. Accordingly, reporting companies are still required to file beneficial ownership information reports (BOIRs). The deadline of March 21, 2025 remains in effect. More information and FAQs may be found on the FinCEN website here.
- FinCEN announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement actions against any companies until an interim final rule is issued (the final rule is expected sometime this month).
- Then, on March 2, 2025, the U.S. Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department is further expected to narrow the scope of the rule to foreign reporting companies only.
While the foregoing gives us reason to believe that CTA reporting requirements may not be enforced against U.S. companies, the law does remain in effect. So, what should you do? We recommend that reporting companies either file their BOIRs by the March 21 deadline or be prepared to do so pending the outcome of the final rule. That said, we recognize that those reporting companies which have contracts with the federal government or which do work with the government may be subject to heightened scrutiny, and, as such, these reporting companies are urged to file by March 21 regardless of the status of enforcement.
Our attorneys will continue to monitor developments regarding the CTA and provide additional information as necessary. For more information about the CTA and its potential impact on you or your business, please contact us at cta@darslaw.com.
