Corporate Transparency Act – Important Revisions
On March 21, 2025, FinCEN released an Interim Final Rule (IFR) that eliminates the beneficial ownership reporting requirements for US Companies and US Persons. Our previous alert in November 2024 gives more detail on the original reporting obligations.
At this time, FinCEN has introduced new deadlines for Foreign Companies.
We have set out below a summary of these new requirements and deadlines:
- The term “reporting company” will refer to entities established under foreign law that are registered to operate in any US State or Tribal jurisdiction by submitting a document to a secretary of state or a similar office (previously referred to as “foreign reporting companies”).
- Foreign entities that fall under the updated definition of a “reporting company” and are not exempt from reporting requirements must submit their BOI to FinCEN by the new deadlines.
The deadlines to reflect these revisions are as follows:
- Following the publication of the interim final rule, the following deadlines apply to foreign entities that are reporting companies:
- Entities registered to do business in the United States before the publication date of the IFR must submit their BOI reports within 30 days of that date.
- Companies that register to do business in the United States on or after the publication date of the IFR must file their initial BOI report within 30 calendar days of receiving notice that their registration has been approved.
Further information
You can read more about this topic in the US Department of the Treasury’s Fact Sheet.
The Interim Final Rule is available here.
You can read the FinCEN release notice dated March 21, 2025 here.
FinCEN issued guidance for small firms here.
How Waystone can help
Waystone Compliance Solutions’ dedicated team of US compliance specialists has extensive experience in assisting firms with their FinCEN obligations. If you require more information on this topic or are interested in learning about our regulatory filing services, please reach out to your usual Waystone representative, or contact us below.