FinCEN Will Not Impose Fines or Penalties for Beneficial Ownership Reporting Deadlines

Takeaways

• By March 21, 2025, FinCEN plans to issue an interim final rule extending BOI reporting deadlines and providing further guidance.

• FinCEN’s announcement to refrain from imposing fines and penalties aligns with the Treasury Department’s commitment to reducing regulatory burdens while prioritizing enforcement against entities posing the most significant law enforcement and national security risks.
• FinCEN will also seek public comment on potential revisions to BOI reporting requirements as part of a forthcoming notice of proposed rulemaking later this year.

The Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or take enforcement actions against companies that fail to file or update their Beneficial Ownership Information (BOI) reports under the Corporate Transparency Act (CTA) by current deadlines. This suspension will remain in place until FinCEN issues an interim final rule and the new deadlines established in that rule have passed.

The CTA rules may undergo further changes as FinCEN plans to solicit public feedback on potential revisions to existing BOI reporting requirements. FinCEN will evaluate these comments as part of a notice of proposed rulemaking expected later this year, aiming to reduce the burden on small businesses while ensuring BOI remains valuable for national security, intelligence, and law enforcement efforts. Additionally, FinCEN will assess whether modifications to the current reporting deadlines are necessary.

This update signals an effort to balance regulatory compliance with the need for clarity and flexibility, particularly for small businesses. Dykema will continue to monitor developments and provide updates on how these changes may impact reporting obligations.

For more information regarding the CTA or how the new developments around the CTA may impact your business, please contact your local Dykema relationship attorney.