As background, beginning January 1, 2024, the CTA imposed a requirement to file BOI with the Treasury’s Financial Crimes Enforcement Network (FinCEN) by January 1, 2025. The reporting includes information for those who directly or indirectly exercise “substantial control” over the reporting entity, or who directly or indirectly own or control 25% or more of the ownership interests of the reporting entity.
We are monitoring the situation as FinCEN and the Department of Justice issue their decision regarding this matter. It is unclear if the preliminary injunction will lead to a change in the January 1, 2025 reporting deadline in the form of an extension to file until January 1, 2026 OR be eliminated altogether. In the meantime, we are advising our clients to weigh complying with the January 1, 2025 deadline despite the Court’s injunction VERSUS not complying with the January 1, 2025 deadline because the Court’s injunction was granted.
Please reach out to us if you have any questions or concerns regarding BOI and its potential impact on your business.
