Beneficial Ownership Information (BOI) 
New Federal Reporting Requirement 

 

 

Your business may need to file a Beneficial Ownership Information (BOI) Report to stay compliant. This report, a new federal reporting requirement, informs the government of who owns your business and helps them prevent financial crimes. Missing the filing deadline could result in criminal and civil penalties. 

 

 

 

Why file BOI?  

The Corporate Transparency Act (CTA) was enacted to combat money laundering and the misuse of shell companies. Filing with the Financial Crimes Enforcement Network helps maintain compliance with the Corporate Transparency Act.   

 

The CTA imposes both civil and criminal penalties for non-compliance 

Civil penalties may include a daily fine of $500 for ongoing violations, up to a maximum of $10,000.  

Criminal penalties can result in up to two years of imprisonment. 

 

 

  

What is BOI? 

Under the CTA, most U.S. companies are required to disclose their beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN).  

 

The report calls for info about your business, business owner, and applicant, as well as copies of official IDs for those individuals. 

 

 

  

When do I file? 

It’s generally filed once by the deadline and again for any ownership changes.  

 

  • Business created before Jan 1, 2024 must file by Jan 13, 2025* 
  • Business created during 2024 must file within 90 days  
  • Business created on or after Jan 1, 2025 must file within 30 days  

 

FinCEN guidelines for filing is available https://boiefiling.fincen.gov/resources/BOIR_Filing_Instructions.pdf 

 

 

What is the latest?

BOI Reporting Put on Hold Yet Again

The U.S. Supreme Court is expected to rule soon on the national injunction issued by a lower court that paused the implementation of the Corporate Transparency Act, a law requiring companies to disclose their true ownership.

 

Companies and trusts aren’t currently obligated to file beneficial ownership information to FinCEN and won’t face liability if they fail to comply when the injunction is active. But companies can still voluntarily file their ownership information as having that info organized is going to be important to comply with other jurisdictions’ requirements and responding to know-your-customer requests.