March 21 Update: CTA Final Rule Narrows Scope

The Financial Crimes Enforcement Network (FinCEN) has finalized new rules under the Corporate Transparency Act (CTA), significantly shifting compliance expectations for U.S. businesses. 

Effective March 21, 2025, the updated rule clarifies that U.S.-based companies and their beneficial owners are no longer required to file or update Beneficial Ownership Information (BOI) reports unless they meet newly defined thresholds, largely targeting foreign entities with U.S. operations. 

This change follows recent court rulings that questioned the CTA’s reach and enforceability. In response, the Treasury Department narrowed the rule’s application and suspended penalties for prior noncompliance by domestic reporting companies. 

Businesses that previously submitted BOI filings may no longer be required to update their reports going forward. However, voluntary filing remains an option for those seeking clarity and future protection. 

For questions on how these changes may affect your reporting responsibilities, contact your ShindelRock team.