FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons

Following the U.S. Department of the Treasury’s March 2, 2025, announcement, the Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA).

Under this interim final rule, FinCEN has revised the definition of a “reporting company” to include only entities formed under the law of a foreign country that have registered to do business in a U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office. These entities, formerly known as “foreign reporting companies,” must still report BOI unless they qualify for an exemption.

Entities created in the United States — previously classified as “domestic reporting companies” — are now fully exempt from BOI reporting requirements. Additionally, foreign reporting companies will not be required to report any U.S. persons as beneficial owners.

For more information, contact Danyal Ahmed or Jessica Manivasager.