The obligation for the majority of small businesses to file their Beneficial Ownership Information (BOI) reports has been reinstated. On February 18, 2025, the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.) lifted the stay that prevented the mandatory filing of BOI reports for impacted small businesses. With the lifting of the stay, small businesses subject to the reporting mandates of the CTA will have until March 21, 2025 to file their BOI reports.
On February 19, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) released an update confirming the reinstated BOI reporting mandates, and provided that it would assess the need to further modify deadlines during the next 30 days to reduce the regulatory burden on small businesses. FinCEN added that it would prioritize reporting for those entitles that pose the most significant national risk and reduce the burden for lower-risk entities. Notwithstanding such considerations, no other details were provided by FinCEN regarding future deadline changes.
What this means for the vast majority of small businesses?
Small businesses subject to BOI reporting must prepare and gather information to file their BOI reports by the new deadline of March 21, 2025, unless granted with a later deadline by FinCEN. The failure to comply with such FinCEN requirements remains harsh, including civil penalties of up to $500 for each day that the violation continues, or criminal penalties, including imprisonment of up to two years and/or a fine of up to $10,000.
The attorneys at O’Reilly Rancilio P.C. will continue to monitor matters regarding BOI reporting and the CTA, and are available to counsel clients on reporting and compliance requirements. Please don’t hesitate to contact Charles E. Turnbull at cturnbull@orlaw.com or Arvin F. Zora at azora@orlaw.com if you have any questions.
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