By Linda R. Brower, Senior Counsel, Commercial Transactions

What Happened

On February 27, 2025, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it would suspend the March 21, 2025 deadline for mandatory reporting of beneficial ownership information (BOI) under The Corporate Transparency Act (Act) — it had issued the week before. The Release states  “[n]o fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.” FinCEN said it will issue the interim final rule extending the BOI reporting deadlines by no later than March 21, 2025.

Finally, FinCEN announced that later this year it intends to solicit public comments on proposed revisions to the existing BOI reporting requirements. It will consider such comments as part of a notice of proposed rulemaking that it expects to balance the burden on small business while still ensuring that BOI remains useful to national security, intelligence, and law enforcement activities.

BMK continues to monitor and report on FinCEN’s announcements and all further developments under the Act as they occur.

This communication is not a full analysis of the matters presented and should not be relied upon as legal advice and could be considered attorney advertising.

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