This Act mandates that certain business entities disclose their beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department. Lawsuits have challenged this Act in the Fourth and Fifth Circuits. The current Federal Administration is unpredictable. Whether or not this Act is enforceable has changed in December 2024, January 7, 2025, and again on January 23, February 10th, February 17th February 27th and March 2nd.
As of March 19, 2025, here is the current situation:
On February 27, 2025, FinCEN announced that it would not issue penalties or fines related to the CTA’s reporting requirements against U.S. citizens or domestic reporting companies, effectively suspending enforcement for these entities. The announcement also stated that “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.”
On March 2, 2025, the Treasury announced suspension of enforcement against U.S. citizens or domestic reporting companies or their beneficial owners and indicated the Treasury’s intention to narrow the scope of reporting requirements to “foreign reporting companies only.”
However, these rules are technically still in effect:
Entities formed before January 1, 2024: Originally required to file by January 1, 2025, these entities now have until March 21, 2025, to submit their BOI report;
Entities formed on or after January 1, 2025: Must file their initial BOI report within 30 days of receiving actual or public notice that their creation or registration is effective.
For businesses that choose to report or that fall outside of the enforcement suspension categories, reporting is handled through the FinCEN’s BOI web page: https://fincen.gov/boi