New FinCEN rule eases CTA reporting for U.S. firms. Foreign companies must act by April 21. Here are new key compliance insights.
SAN DIEGO, CALIFORNIA – In our last client alert on March 11, 2025, we noted that the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) was considering yet another policy change concerning the Corporate Transparency Act (“CTA”) and the requirements of reporting companies to report on their beneficial ownership.
As of March 21, 2025, FINCEN indeed promulgated a new interim final rule (“Interim Rule”), which now largely exempts all domestic entities from their CTA reporting requirements. Entities formed outside of the U.S., though doing business in the U.S., and thus generally required to register to do business in the U.S. jurisdictions where such entities are in fact doing business, must still file CTA Beneficial Ownership Information Reports (“BOIRs”). If such foreign entities were formed prior to March 21, 2025, such entities must file their BOIRs within thirty (30) days, thus no later than April 21, 2025.
Foreign entities formed after March 21, 2025 must file within thirty (30) days of formation. However, in either case for such foreign reporting entities, BOIRs concerning U.S. beneficial owners are not required to be reported on, only such entities’ foreign beneficial owners.
Klinedinst PC will continue to monitor the CTA and news from FinCEN, along with CTA related litigation that may affect the compliance requirements for our clients. If you have any questions or comments regarding the CTA and BOIRs, you are encouraged to reach out and consult with counsel.
To learn more about the CTA, or to contact a member of the transaction team, please visit:
klinedinstlaw.com/practice/corporate-transparency-act
Note
This update on the CTA is provided as-is and does not constitute legal advice, and should not be relied upon as such. You are encouraged to consult with your attorney with any questions.
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