On February 18, 2025, a decision by a U.S. District Court lifted the last remaining nationwide injunction that halted the Beneficial Ownership Information (“BOI”) reporting requirements. The Financial Crimes Enforcement Network (“FinCEN”) has set the new deadline to file to March 21, 2025; however, companies that were previously given a later deadline may file by that later date. FinCEN has stated that it will assess its options to further modify deadlines as it intends to prioritize reporting for entities that pose the most significant national security risks.

A person who willfully violates the BOI reporting requirements may be subject to civil penalties of up to $606 for each day that the violation continues and may also be subject to criminal penalties of up to two years imprisonment and a fine of up to $10,000. Potential violations include willfully failing to file a BOI report, willfully filing false BOI, or willfully failing to correct or update previously reported BOI. 

Efforts are still ongoing to try and pass the Repealing Big Brother Overreach Act that would repeal the Corporate Transparency Act (“CTA”), meaning there would be no BOI reporting. However, the likelihood of the Repealing Big Brother Overreach Act passing is uncertain. We will keep you updated on any changes to the reporting deadlines.