Following the entry of an order by the U.S. District Court for the Eastern District of Texas on February 17, 2025, the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect and are being enforced by the Financial Crimes Enforcement Network (FinCEN). As a reminder, any person who willfully fails to file a BOI report (or files a BOI report late) may be subject to civil penalties of $606 for each day that the violation continues, and criminal penalties of up to two years imprisonment and a fine of up to $10,000.
In response, FinCEN has extended the deadline for most reporting companies to file an initial, updated, and/or corrected BOI report to March 21, 2025. The updated reporting deadlines are as follows:
| Reporting Company Formation or Registration Date | Updated Filing Deadline |
| Prior to January 1, 2024 | March 21, 2025 |
| Between January 1, 2024, and December 31, 2024 | The later of March 21, 2025 or 90 days from formation/registration |
| On or after January 1, 2025 | The later of March 21, 2025 or 30 days from formation/registration |
While FinCEN has indicated that it may further modify BOI reporting deadlines, reporting companies that have yet to file a BOI report should do so before the applicable updated deadline indicated above.
Reporting companies can file their BOI report directly with FinCEN using FinCEN’s E-Filing system available at https://boiefiling.fincen.gov.
If you have any questions or would like more information on the content discussed in this communication, please contact any member of our Corporate Practice Area.
