CTA Reporting – Latest Developments
U.S. Companies and U.S. Persons Exempt From Beneficial Ownership Reporting
04/02/2025
On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued interim final rules which exempt U.S. reporting companies (corporations, LLC’s and partnerships that were created by the filing of a document with a secretary of state or similar office) from filing a beneficial ownership information report (“BOIR”) even if any beneficial owner of such entity is a non-U.S. person.
Each foreign reporting company registered to do business in the United States will have to file a BOIR but will not be required to provide beneficial ownership information concerning U.S. persons who are beneficial owners of such foreign reporting company; and U.S. persons will not be required to report beneficial ownership information to such company. Accordingly, foreign reporting companies whose only beneficial owners are U.S. persons will be exempt from the requirement to report any beneficial owners.
Foreign reporting companies in existence prior to the March 21st announcement, who are not exempt from the reporting requirements, must file their BOIR with the FinCEN no later than 30 days from March 21, 2025. Any entity that becomes a foreign reporting company on or after March 21 will be required to file a BOIR within 30 days from the date of receiving notice that it is registered to do business in the U.S.