Back in 2023, we wrote about of the enactment of the Corporate Transparency Act (CTA) and the obligation imposed on all entities organized under the laws of the United States and/or foreign entities conducting business in the United States (with certain exceptions such as non-for-profits and public companies, among others) to file the Beneficial Ownership Information (BOI) report starting in January 2024. Having entered into effect, millions of companies filed the BOI report, disclosing the shareholders with over 25% ownership and individuals with control over the companies’ decision-making process, but after months of different legal battles challenging the validity and enforcement of the CTA and BOI, on March 21, 2025 the Financial Crimes Network (FinCEN), issued an interim final rule that removes the requirement for US companies and US persons to file the BOI report. This FinCEN rule revises the term “reporting company” as those entities that are formed under the laws of a foreign jurisdiction and register to conduct business in the United States. Therefore, the long anticipated and short-lived BOI report, will no longer be part of the list of compliance and reporting obligations for US companies. The remaining question is what FinCEN and the Department of the Treasury (i.e. the US Government) will do with the information gathered from the millions of companies and individuals while the BOI was in effect. 

Article by Andres Bazo, Foreign Legal Consultant at Rasco Klock Perez & Nieto, P.L.