Hunton Retail Law Resource

FinCEN has now finalized the significant narrowing of the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements that it first adopted on an interim basis in March 2025, including removing the requirement for updating information provided for FinCEN identifiers. At the same time, the constitutional challenge to the CTA remains pending, with a petition asking the US Supreme Court to review the Eleventh Circuit’s decision upholding the statute. For US companies and US persons, the practical takeaway is simple: For now, there is no CTA BOI reporting obligation.

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that exempts all domestic companies and persons from all Corporate Transparency Act (CTA) requirements. The only entities remaining in scope are ones that were formed under the laws of a foreign jurisdiction and subsequently registered to do business in a U.S. jurisdiction.