Dear Client,
Following the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., the Financial Crimes Enforcement Network (FinCEN) has reinstated the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA).
Updated Deadline
Most reporting companies must now file their BOI reports by March 21, 2025. However, it is unclear whether any further changes will apply.
Who Needs to File?
All U.S. companies and foreign entities registered to do business in the U.S. must comply with BOI reporting requirements unless exempt under the CTA.
Potential Consequences of Non-Compliance
Failure to comply with BOI reporting obligations may result in substantial penalties, including civil and criminal fines of up to $10,000 and potential imprisonment for up to two years.
What Needs to Be Done?
• Determine whether your entity needs to report the BOI or is exempt.
• Verify whether your entity possesses an EIN number, as it is required to comply with this obligation.
• Verify the structure and information of Beneficial Owners or Controling Persons and proceed to file the report on the FINCEN BOI website.
OMC GROUP can assist with BOI compliance by providing guidance and support in the following areas:
• Assess whether your entity falls within the scope of BOI reporting obligations under the Corporate Transparency Act.
• Facilitate the acquisition of an Employer Identification Number (EIN), a prerequisite for compliance with BOI reporting requirements.
• Ensure the accurate and timely submission of your BOI report to mitigate the risk of regulatory penalties or enforcement actions.
With the March 21, 2025, deadline approaching, we encourage you to take the necessary steps to ensure timely compliance and avoid penalties.
