New BOI Reporting Requirement for Businesses

As of January 1, 2024, the bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information to the Financial Crimes Enforcement Network (FinCEN) about the individuals who ultimately own or control them. FinCEN is a bureau of the U.S. Treasury Department.

Filing is simple, secure, and free of charge. Beneficial ownership information reporting is not an annual requirement. A report only needs to be submitted once, unless the filer needs to update or correct information.

Companies that are required to comply (“reporting companies”) must file their initial reports by the following deadlines:

• Existing companies: Reporting companies created or registered to do business in the United States before January 1, 2024 must file by January 1, 2025.
• Newly created or registered companies:
  • Reporting companies created or registered to do business in the United States in 2024 have 90 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective.
  • Beginning in 2025, newly created or registered companies will have 30 days.

Who needs to file?

A company may need to report beneficial ownership information to FinCEN if it is:

• a corporation, a limited liability company (LLC), or was otherwise created in the United States by filing a document with a secretary of state or any similar office under the law of a state or Indian tribe; or
• a foreign company that was registered to do business in any U.S. state or Indian tribe by such a filing.

• For more information about whether a company needs to file, visit fincen.gov/boi.

Companies can file at https://boiefiling.fincen.gov or visit https://www.fincen.gov/boi for more information.