In 2021, the U.S. Congress passed the Corporate Transparency Act (CTA) to enhance transparency and combat financial crimes. After legal challenges, the CTA is now being enforced, requiring companies registered in the U.S. to provide their Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN).
Latest legal proceedings
On February 17, 2025, the U.S. District Court for the Northern District of Texas overturned a previous injunction in the case of Samantha Smith v. U.S. Department of the Treasury. This decision reactivates the enforcement of the CTA. FinCEN has released an anticipated filing deadline of March 21, 2025. It is important to view the official notice from FinCEN here.
“No later than March 21, 2025, FinCEN intends to issue an interim final rule that extends BOI reporting deadlines, recognising the need to provide new guidance and clarity as quickly as possible, while ensuring that BOI that is highly useful to important national security, intelligence, and law enforcement activities is reported.” – FinCen.
While a proposed bill in Congress could extend the filing deadline to January 1, 2026, the legislation’s future remains uncertain. Family offices should not rely on this potential extension and should proceed as if the March 21, 2025, deadline will remain in effect. Family offices structured through trusts, holding companies, or special-purpose vehicles must be prepared for compliance.
How family offices can prepare for BOI Compliance
This short compliance window presents significant challenges for family offices managing complex ownership structures. Advanced preparation is crucial to avoid last-minute reporting burdens.
Even as litigation continues, BOI reporting remains a federal requirement under the CTA. Family offices should take the following steps to ensure readiness:
- Identify beneficial owners – Determine individuals who meet the definition of “beneficial owner” under CTA rules.
- Gather necessary information – Collect the required personal and entity data for reporting.
- Review FinCEN’s guidelines – Stay updated on reporting obligations and exemptions.
- Consult legal and compliance advisors – Ensure that your reporting strategy aligns with the latest regulatory interpretations.
Proactively addressing BOI compliance can help mitigate risks associated with last-minute regulatory shifts
Staying informed
Family offices, trustees, and legal advisors need to stay informed due to multiple legal challenges and ongoing regulatory changes. Subscribe to updates on CTA compliance, BOI reporting, FinCEN enforcement actions, and other relevant areas to ensure compliance. Reliable compliance platforms like FileForms offer resources like weekly webinars, with the next one scheduled for March 12, 2025, to help stay up-to-date on evolving regulations.
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.
