Beneficial Ownership Information (BOI) Reporting Update

If you’ve been paying attention to the news surrounding the beneficial ownership information (BOI) reporting requirement under the Corporate Transparency Act (CTA), then you know that it has undergone many changes. It was implemented in 2024, paused for legal challenges, reinstated, paused again and, most recently, reinstated again, but without enforcement.

Our last communication regarding the BOI, sent out on December 30, 2024, stated that reporting was not required at that time. On February 18, 2025, the BOI reporting requirements were put back in effect with a deadline of March 21, 2025. However, the U.S. Treasury Department issued a statement on March 2, 2025 announcing that it would not enforce penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners under the Corporate Transparency Act. Furthermore, the agency is actively working to narrow the scope of the BOI reporting rule to include “foreign reporting companies only.” For further details, click on the link to read the U.S. Treasury Department’s statement.

We continue to encourage you to consult with your legal counsel as soon as possible to discuss your company’s potential reporting requirements. Currently, BMSS is not providing BOI consulting or filing services.

You can find more information on the BOI filing requirement, as well as the link to file your entity’s report, if you choose to do so, on the FinCEN website at www.fincen.gov/boi.