According to an updated Jan. 2 statement from the Financial Crimes Enforcement Network: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”

SCOTUS has ordered the plaintiffs to respond to FinCEN’s application no later than 4:00 p.m. EST on Friday, January 10, 2025. Once the plaintiffs’ response is filed, a SCOTUS decision on FinCEN’s application could be issued at any time.

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September 2023

Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners—the individuals who ultimately own or control the company. Companies will be able to begin reporting beneficial ownership information to FinCEN at that time.

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued additional guidance materials for the beneficial ownership information (BOI) reporting requirements:

Small Entity Compliance Guide  https://www.fincen.gov/sites/default/files/shared/BOI_Small_Compliance_Guide_FINAL_Sept_508C.pdf

An Introduction to Beneficial Ownership Information Reporting  https://www.fincen.gov/sites/default/files/shared/BOI_FinCEN_Brochure_508C.pdf

FAQ - Beneficial Ownership Information https://www.fincen.gov/sites/default/files/shared/BOI_FAQs_Q&A_09.29.23._508C.pdf