On February 27, 2025, the Financial Crimes Enforcement Network ("FinCEN") announced that it will not issue any fines or penalties or initiate any other enforcement action against companies that do not file or update beneficial ownership information ("BOI") reports under the Corporate Transparency Act ("CTA") by the newly-instated March 21, 2025 deadline.
As discussed in our last update, the CTA's reporting obligations went back into effect on February 17, 2025, after a federal judge lifted a preliminary injunction that had previously blocked the law's enforcement. Several days later, FinCEN issued a statement alerting reporting companies that the deadline to file BOI reports would be extended by thirty days to March 21, 2025.
Now, FinCEN says that no later than March 21, 2025, it plans to issue an "interim rule" that will provide new guidance on CTA reporting obligations, with new deadlines for reporting companies. This latest statement comes as the Treasury Department has stated it is committed to minimizing regulatory burden on small businesses and prioritizing CTA enforcement for only those entities that pose the most significant law enforcement and national security risks.
In light of FinCEN's announcement, KMK recommends that companies assess whether they want to continue filing any required BOI reports under the current CTA, or rely on FinCEN's guidance that reporting companies will not face enforcement action until the "interim rule" is effective.
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