TREASURY NARROWS CTA SCOPE TO FOREIGN REPORTING COMPANIES
April 7, 2025
Eckert Seamans has prepared the information in this update for educational purposes only. It does not constitute legal advice nor substitute for legal advice. Neither your receipt of information from this website nor your use of this website to contact Eckert Seamans or one of its attorneys creates an attorney-client relationship, as the firm may, for example, already represent another party involved in your matter. Accordingly, you should not provide confidential information to Eckert Seamans. Persons seeking legal advice should consult a licensed professional attorney in their state. The firm’s Terms of Use, Legal Notice, and Disclaimer detailed herein are expressly incorporated into the Aviation Regulatory Update.
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.
This Aviation Blog is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Patrick Bornstein at 407.625.4050 or pbornstein@eckertseamans.com, Jay Julien at 202.659.6648 or jjulien@eckertseamans.com; or Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
Share This Post
Authors
