The Financial Crimes Enforcement Network of the U.S. Treasury
Department (FinCEN) announced a new deadline for most companies
covered by the Corporate Transparency Act (CTA). Such reporting
companies now must file Beneficial Ownership Information (BOI)
reports no later than March 21, 2025.
FinCEN made its announcement on February 18, 2025, in response to a
decision by a federal judge in the U.S. District Court for the
Eastern District of Texas lifting the preliminary injunction in
Smith v. United States Department of the Treasury. That
decision removed the last judicial impediment to the enforcement of
the CTA. With limited exceptions for certain reporting companies
qualifying for an extension due to disaster relief or who may be
subject to an exception as a plaintiff in National Small
Business United v. Yellen, reporting companies should file
their BOI reports no later than March 21, 2025. As of today, the
deadline appears firm and should be considered binding. However, in
its announcement, FinCEN left itself the option of extending the
deadline if it determines an extension is warranted, indicating
that it would provide an update of any modification of the March
21, 2025, deadline prior to that date, recognizing companies
impacted by this announcement may need additional time to comply
with their BOI reporting obligations.
In light of the March 21, 2025, time frame, companies should take heed of this decision and make every effort to meet this reporting deadline.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
