FinCen BOI Report

FinCen Beneficial Ownership Reporting Requirement

Learn what you need to file.

What is a FinCen BOI Report?

In 2021, the U.S. Congress enacted the Corporate Transparency Act (CTA). Under this law, foeign owned companies must file a reporting document with the Financial Crimes Enforcement Network (FinCEN) to disclose information about their beneficial owners. Beneficial owners are the individuals who ultimately own or control the company.

Important Update 12/3/2024: On Tuesday, December 3, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), a federal district court in the Eastern District of Texas, issued an order granting a nationwide preliminary injunction against enforecment of the CTA.

Important Update 12/05/2024: The Department of Justice, on behalf of the Department of the Treasury, filed a notice of appeal on December 5, 2024.

Important Update 12/17/2024: On December 17, 2024, the district court denied the U.S. Government’s motion to stay the preliminary injunction.

Important Update: 12/23/2024: On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit blocked the Eastern District of Texas court's injunction, meaning that business owners again needed to file their BOI reports.

Important Update 12/26/2024: On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the nationwide injunction and currently business owners are not required to file their BOI reports.

Important Update 05/26/2025: Under the Trump administration's policy of deregulation, a March 2025 FinCEN interim final rule (effective March 26, 2025) removed the beneficial ownership reporting requirements for most U.S. companies and U.S. persons under the CTA. The final rule exempts all entities created in the U.S.—including domestic reporting companies—from the BOI reporting requirements. This means companies we create in the U.S. for our foreign clients are exempted.

Staying Up-to-Date on the Law: Subhan Law shall continue to monitoring any new developments closely and guide our clients on the approach we believe that is in their best interests.