May 2025Transmittal 531
Effective: 5/1/2025
Banks and Banking
Bank Secrecy Act Regulations
The U.S. Department of the Treasury’s Financial Crimes Enforcement
Network (FinCEN) adopted an interim final rule to narrow the existing
beneficial ownership information (BOI) reporting requirements under
the Corporate Transparency Act to require only entities previously
defined as “foreign reporting companies” to report BOI.
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Under this interim
final rule, entities previously defined as “domestic reporting companies”
are exempted from the reporting requirements and do not have to report
BOI to FinCEN, or update or correct BOI previously reported to FinCEN.
With limited exceptions, the interim final rule does not change the
existing requirement for foreign reporting companies to file BOI reports.
However, the interim final rule exempts foreign reporting companies
from having to report the BOI of any U.S. persons who are beneficial
owners of the foreign reporting company and exempts U.S. persons from
having to provide such information to any foreign reporting company
for which they are a beneficial owner. The interim final rule is effective
March 26, 2025 (Department of the Treasury, Financial Crimes Enforcement Network), the same day it was published in the Federal Register. FinCEN is accepting
written comments on this interim final rule through May 27, 2025.
FinCEN will assess the exemptions, as appropriate, in light of those
comments and intends to issue a final rule this year.