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In 2021, the U.S. Congress enacted the Corporate Transparency Act (CTA) to enhance corporate transparency and prevent financial crime. After a series of legal challenges and temporary injunctions, enforcement has now resumed as of March 27, 2025. All U.S.-registered entities, including family offices, must submit Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN) in compliance with the law.
Latest legal proceedings
On March 27, 2025, the CTA was fully reinstated following a complex series of federal court decisions that reversed earlier injunctions. BOI reporting is now active and mandatory for all qualifying entities, and family offices should proceed with compliance without delay.
While FinCEN previously indicated that it would issue an interim final rule by March 21, 2025, to possibly adjust BOI deadlines, no such extension has been enacted. FinCEN continues to expect full compliance based on current timelines.
A bill introduced in Congress proposed extending the initial BOI filing deadline to January 1, 2026. However, the bill remains inactive, and there is no official delay. Family offices should continue preparing for compliance under the current regulations and deadlines.
How family offices can prepare for BOI Compliance
The reinstated reporting timeline presents real challenges for family offices, particularly those with layered structures involving trusts, holding companies, and special-purpose vehicles. Preparing ahead is critical to avoid penalties and ensure accurate filings.
Despite ongoing litigation in various jurisdictions, FinCEN has clarified that BOI reporting under the CTA is enforceable and required. Family offices should follow these steps to ensure compliance:
- Identify beneficial owners – Clarify which individuals qualify under FinCEN’s criteria.
- Gather required information – Collect full legal names, dates of birth, addresses, and identification documents.
- Review the latest FinCEN guidance – Ensure your team is using up-to-date information.
- Consult legal and compliance advisors – Get professional advice to interpret CTA requirements for your structure.
Taking early action on BOI compliance reduces the risk of rushed or incorrect filings and protects family offices from potential enforcement actions or reputational damage.
Staying informed
With legal interpretations evolving and deadlines subject to judicial and administrative changes, staying informed is critical. FileForms provides a trusted compliance platform offering guided workflows, automated document preparation, and weekly webinars to help family offices stay ahead of reporting obligations.
About FileForms
FileForms is a trusted technology platform designed to streamline compliance with Annual Report filings, Registered Agent services, Entity Formations, and BOI reporting. Our secure platform helps organisations efficiently manage large volumes of legal entities, ensuring compliance with both state and federal requirements—all from a single, user-friendly dashboard.
