Lisa and the Law

FinCEN issues Interim Final Rule stating that there will be no CTA enforcement against domestic reporting companies and U.S. persons.

Posted on March 21, 2025

FinCEN issued an Interim Final Rule indicating that no domestic reporting company or U.S. person would be subject to the enforcement of the CTA. The CTA remains law, but FinCEN and the Dept. of Treasury are not going to enforce it against domestic reporting companies or U.S. persons that are beneficial owners of a foreign reporting company. Any filing of BOIRs by domestic reporting companies or U.S. persons is strictly voluntary. Nonexempt foreign reporting companies have until April 25, 2025, to file their initial BOIR. The “Interim Final Rule: Questions and Answers” authored by FinCEN may be found at https://www.fincen.gov/boi/ifr-qa.

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