Reporting of Beneficial Ownership Information
Please note that U.S. Department of Treasury beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury has advised they are appealing that order. The Treasury advised that, in the meantime, reporting companies are not currently required to file a Beneficial Ownership Information Report and are not subject to liability if they fail to do so while the applicable order remains in force.
However, reporting companies may still opt to file a BOIR.
More information is available on the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) website (https://www.fincen.gov/boi).
Beginning January 1, 2024, certain types of corporations, limited liability companies, and other similar entities created in or registered to do business in the United States must report information about their beneficial owners—the persons who ultimately own or control the company—to the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Additional information about the reporting requirements, including answers to questions such as “is my company required to report beneficial ownership information to FinCEN,” “who is a beneficial owner,” and “when do I need to report my company’s beneficial ownership information" is available on FinCEN’s beneficial ownership information webpage, FinCEN.gov/BOI. You can also subscribe to FinCEN Updates for future guidance documents.
FinCEN’s BOI webpage provides:
- A Small Entity Compliance Guide;
- Answers to Frequently Asked Questions;
- Infographics, such as the following about Key Filing Dates; and
- An introductory video and more detailed informational video, available at FinCEN.gov/BOI.
Alert: FinCEN has been notified of recent fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act. The fraudulent correspondence may be titled "Important Compliance Notice" and asks the recipient to click on a URL or to scan a QR code. Those e-mails or letters are fraudulent. FinCEN does not send unsolicited requests. Please do not respond to these fraudulent messages, or click on any links or scan any QR codes within them.
A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025 to file its initial beneficial ownership information report.
A reporting company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 calendar days after receiving notice of the company’s creation or registration to file its initial BOI report. This 90-calendar day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.
Reporting companies created or registered on or after January 1, 2025, will have 30 calendar days from actual or public notice that the company’s creation or registration is effective to file their initial BOI reports with FinCEN.
