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Beneficial Ownership Information Reporting Mandate Reinstated

The Financial Crimes Enforcement Network (FinCEN) has reinstated the requirement for beneficial ownership information (BOI) reporting, with a new filing deadline of March 21, 2025. This decision follows the U.S. District Court for the Eastern District of Texas’s ruling on February 18, 2025, which lifted the preliminary injunction previously imposed in the Smith case. (Smith, et al. v. U.S. Department of the Treasury, et al., Case No. 6:24-cv-00336).

The updated deadline applies to most reporting companies, requiring them to submit an initial, updated, or corrected BOI report, including entities established before January 1, 2024. Entities formed in 2025 must comply by the later of March 21, 2025, or 30 days from their formation date.

FinCEN has stated that over the next 30 days, it will evaluate potential deadline modifications while prioritizing compliance for entities that pose higher national security risks. Additionally, FinCEN plans to revise the BOI reporting rule later this year to ease the burden on lower-risk entities, particularly small businesses in the U.S.