Corporate Transparency Act: FinCEN Pauses Enforcement, Penalties Pending Further Updates
- 2.28.2025
By: Matteo de Suduiraut, Ben Goldfein, C. S. Avery Reaves and Jonathan Wolfman
Entities subject to the beneficial ownership information (“BOI”) reporting requirements of the Corporate Transparency Act (the “CTA”) may finally find their footing after receiving updated guidance from the Financial Crimes Enforcement Network (“FinCEN”). As previously discussed, as of February 18, 2025, BOI reporting requirements under the CTA are back in effect, with filing deadlines for most reporting entities being extended to March 21, 2025.
On February 27, 2025, FinCEN announced that it will neither issue any fines or penalties nor take any other enforcement action against companies for failing to file or update BOI reports by the current March 21 deadline. FinCEN intends to issue an interim final rule on or before March 21, 2025, that extends BOI reporting deadlines. Additionally, FinCEN plans to solicit public comments to existing BOI reporting requirements to determine how to enforce the CTA while minimizing the burden of the reporting requirements on small businesses.
As we wait for FinCEN’s updated guidance on the BOI reporting deadline, entities subject to the BOI reporting requirements should continue to gather information needed for their respective BOI reports.
