Beneficial Owner Information Filing Requirements are Back Compliance Due March 21, 2025

Just this week, there was a new ruling in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336. This decision in effect removed the stay preventing the enforcement of the Beneficial Ownership Report regulations at 31 C.F.R. 1010.380 (the “BOI Regulations”) under the Corporate Transparency Act (“CTA”). The United States Department of the Treasury’s Financial Crimes Enforcement Network or “FinCEN” has now issued a response to the ruling.

In an update to their website, they stated that “…beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect.” However, due to the prior injunctions, the Department of the Treasury did recognize that reporting companies may need additional time to comply with their BOI reporting obligations.

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 indicates that it 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.

The FinCEN alert may be accessed here: https://fincen.gov/boi.

If you already filed your required BOI reports, this news does not affect you. If you have not filed any required report, given what we know today about the window for compliance, there may be delays on the filing website. You are encouraged to file promptly. You may contact your Farmer Scott Ozete Robinson & Schmitt, LLP attorney if you need help in filing; however, with the short compliance window and the time that it takes to gather the required information, you should do so immediately.