FinCEN BOI Reporting Now on Hold Again
On December 24, we updated you on FinCEN Beneficial Ownership Information (BOI) filing requirements following the Fifth Circuit Court of Appeals’ reinstatement of the reporting mandate.
Developments since then have shifted the situation once more.
The Fifth Circuit Court of Appeals has vacated its stay, placing the FinCEN BOI filing requirements back on hold.
What This Means for You
As of now, the BOI filing deadlines are uncertain, and entities previously subject to the January 13, 2025, compliance date no longer have a binding deadline.
Key Points
- BOI Filing on Hold: Reporting requirements are paused until further notice. This includes all entities previously required to file by January 13, 2025.
- Await Further Guidance: FinCEN has committed to providing updated instructions once the legal issues are resolved.
What You Should Do
- Stay Informed: Monitor updates from FinCEN and the courts to ensure compliance when a final ruling is issued.
- Prepare in Advance: While the requirements are on hold, reviewing your entity’s readiness for potential future compliance can save time and reduce risk.
- Consider Filing Now: Filing now eliminates the risk of penalties. Waiting for the court’s decision may leave you unprepared or unable to file in a timely manner.
Why It Matters
Compliance remains critical. Once the courts and FinCEN resolve the situation, failure to meet filing requirements could result in:
- Civil penalties of $591 per day,
- Criminal fines of up to $10,000, and
- Up to two years in prison.
Reference for You
