FINCEN BOI BACK IN EFFECT 2/27/2025

FINCEN BOI REPORTING BACK IN EFFECT

FinCEN Beneficial Ownership Information Reporting (“BOIR”) is back in effect as of February 18th, 2025, following a decision to stay the District Court for the Eastern District of Texas’ ruling to enjoin enforcement of the act until the appeals process has been finalized. On February 19th, 2025, FinCEN issued an alert stating that they will be granting an additional thirty (30) day extension for reporting. For most entities created prior to 2024 (“Existing Entities”) that are not subject to hurricane relief, this extension grants time to file until March 21st, 2025. Although FinCEN indicated that penalties for failure to comply are not being assessed at this time, we recommend compliance prior to the deadline. We are contacting the affected clients who previously engaged us for this work and will work to file the BOI reports prior to March 21, 2025.

For those Existing Entities that are subject to hurricane relief (most entities with principal place of business in South or Central Florida), the deadline remains July 1, 2025. We will be contacting these clients in May/June to complete the BOIR, assuming the law is still in effect at that time.

For those entities subject to hurricane relief and created after January 1, 2024, (“Newly Formed Entities”) with a due date falling between October 4, 2024, and January 2, 2025, a six (6) month extension has been granted. For example, a Newly Formed Entity created on July 25th, 2024, with an original reporting due date of October 23rd, 2024, now has until April 23, 2025, to submit the initial report. All other Newly Formed Entities have 30 days to file an initial BOIR.

If you would like to discuss your circumstances, please reach out to our office at your convenience.

Thank you,

Joseph C. Kempe, Esq.