On February 6, 2025, the Financial Crimes Enforcement Network ("FinCEN") published an alert announcing that it has filed a Notice of Appeal in Smith v. U.S. Department of the Treasury, which enjoined the enforcement of Beneficial Ownership Information ("BOI") Reporting requirements nationwide. Importantly, the alert also confirmed that FinCEN will provide a thirty-day extension for submitting BOI Reports in the event that the court stays the Smith injunction. FinCEN also indicated that it will consider modifying deadlines and the scope of Reporting Companies with the goal of reducing the burden on small business owners that pose minimal risk. "FinCEN, during that 30-day period, will assess its options to modify further deadlines or reporting requirements for lower-risk entities, including many U.S. small businesses, while prioritizing reporting for those entities that pose the most significant national security risks." We will provide further updates about the status of the BOI reporting deadline as they become available.
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