Update: 3/24/25

As predicted, FinCen revised its March 21st deadline. FinCen has issued an interim final rule that revises the definition of “Reporting Company” to essentially foreign companies. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed below.

Upon the publication of the interim final rule, the following deadlines apply for foreign entities that are reporting companies:

• Reporting companies registered to do business in the United States before the date of publication of the IFR must file BOI reports no later than 30 days from that date.
• Reporting companies registered to do business in the United States on or after the date of publication of the IFR have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

This rule is an interim final rule so we will keep you informed of further developments. In the meantime, do not hesitate to reach out if you have any questions or concerns.

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