We are providing another important update on the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements.
In announcements on February 27 and March 2, the U.S. Treasury Department indicated that it does not intend to enforce the CTA’s BOI reporting rules and deadlines for U.S. entities, and enforcement will be limited only to foreign reporting companies. Therefore, foreign reporting companies who have not yet filed BOI reports should continue to do so, while U.S. reporting companies are unlikely to face penalties for failing to file.
The Treasury Department also indicated a new rule detailing revised BOI reporting deadlines and other guidance will be announced no later than March 21. We will monitor this rulemaking process and will provide further updates on CTA enforcement as they arise.