Following the February 18, 2025 ruling by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have been reinstated. In response, the Financial Crimes Enforcement Network (FinCEN) has announced that BOI reporting is once again in effect, with an extended reporting deadline of March 21, 2025, for most companies.
In a February 19, 2025 notice, FinCEN further indicated that it is evaluating additional modifications to reporting deadlines, prioritizing enforcement for entities that pose the highest national security risks. FinCEN has also indicated that it intends to initiate a rulemaking process this year to ease compliance burdens for lower-risk entities, including many U.S. small businesses.
With these developments, reporting companies should take immediate steps to comply with the reinstated BOI filing requirements and stay informed of any further regulatory updates from FinCEN.
