FinCEN Issues Interim Final Rule for BOI Reporting Requirements

On March 21, 2025 FinCEN issued an interim final rule that removes the BOI reporting requirements for many U.S. companies and U.S. persons. Under the new rule, “reporting company” now means only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. stat or tribal jurisdiction. Thus, companies formed in the U.S. (formerly known as “domestic reporting companies”), and their beneficial owners, will not be required to report BOI to FinCEN. While foreign entities that meet the new definition of a “reporting company” will be required to report BOI to FinCEN, such reporting requirements do not include any U.S. persons that are beneficial owners. In other words, U.S. persons will not be required to report BOI to FinCEN with respect to any entities for which they are a beneficial owner (regardless of what that entity is a “reporting company” or not). New deadlines were imposed for entities that meet the new definition of “reporting company.” For more information, please see here.