TREASURY NARROWS CTA SCOPE TO FOREIGN REPORTING COMPANIES
April 7, 2025
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On March 26, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) adopted an interim final rule narrowing the Corporate Transparency Act’s (“CTA”) beneficial ownership information (“BOI”) reporting obligations to foreign companies. Backlash from small businesses nationwide prompted FinCEN to revise the requirements such that it will not enforce BOI guidelines or penalties against U.S. citizens or domestic reporting companies. After months of uncertainty, legal challenges, and shifting compliance deadlines, domestic and foreign reporting companies sought relief from the never-ending CTA roller coaster. Unfortunately, the twists and turns are far from over for foreign reporting companies. Unless legal action is taken to suspend or overturn the interim final rule, non-exempt foreign reporting companies must submit initial BOI reports or update previously reported BOI by April 25, 2025.
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