On March 2, 2025, the U.S. Department of the Treasury announced a suspension of enforcement for certain reporting requirements under the Corporate Transparency Act (CTA). Effective immediately, U.S. citizens and domestic reporting companies will not be subject to penalties for noncompliance with beneficial ownership information (BOI) reporting obligations.

This policy shift comes as the Treasury prepares to issue a proposed rulemaking that would limit the CTA’s scope to apply only to foreign reporting companies. Treasury Secretary Scott Bessent emphasized that this decision aligns with the administration’s goal of reducing regulatory burdens on small businesses and simplifying compliance obligations.

This suspension means companies are no longer penalized for not meeting the March 21st deadline for filing their BOI reporting, but should continue to prepare for filing by March 21st. Companies should bear in mind that FinCen has indicated it will be making changes to the CTA before the March 21st deadline which could impact what has to be filed, who has to file and by when they have to file. We will advise you of any changes as they are issued.

Suggested follow-up actions

Determine reporting status: assess whether your company qualifies as a reporting company under the CTA. Generally, corporations, limited liability companies, and similar entities created or registered to do business in the U.S. are required to report, unless exempted.

Gather beneficial ownership information: Collect the necessary information for each beneficial owner, including:

• Full legal name
• Date of birth
• Residential or business address
• A unique identifying number from an acceptable identification document (e.g., non-expired U.S. driver's license, passport)

Be prepared to file the required information using FinCEN’s secure E-Filing system. Filing is free of charge.

Additional resources

• FinCEN BOI reporting webpage: Comprehensive information and guidance on BOI reporting requirements.
• Small entity compliance guide: Designed to assist small businesses in understanding and complying with BOI reporting obligations.
• For the official Treasury announcement, visit: Treasury Press Release.

FINCEN has mentioned they will be seeking public commentary regarding this issue, but they have not yet revealed how they will solicit comments.

We will continue to monitor this situation closely and send out up to date requirement information. Please contact our Corporate Transparency Act Compliance Team using the form below, if you have any questions.