An Apparent End to the BOIR Saga – BOIR Reporting No Longer Required for U.S. Persons and U.S. Companies

On Friday, March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued its long-awaited interim final rule (IFR) on beneficial ownership information reporting (BOIR) requirements. The rule, in relevant part, confirms that all entities created in the United States, including those previously known as “domestic reporting companies,” and their beneficial owners will be exempt from the requirement to file BOIRs with FinCEN.

What Now?

For domestic reporting companies and U.S. persons, there is now no need to file BOIRs with FinCEN as previously required in the not-so-distant past.

However, under the IFR, foreign reporting companies must file BOIRs with FinCEN within 30 days of the IFR’s publication in the Federal Register or 30 days after their registration to do business in the United States, whichever comes later. A foreign reporting company is a corporation, limited liability company, or other entity formed under the laws of a foreign country that has registered to do business in the United States.

For more information regarding BOIR filing compliance in light of this new rule, please contact Jake Keller at Fonss & Estigarribia LLP at jbk@fellplaw.com and (858) 746-6488.

DISCLAIMER: This blog is made available by Fonss & Estigarribia LLP (“FELLP Law” or “the Firm”) for informational purposes only. It is not meant to convey the Firm’s legal position on behalf of any client, nor is it intended to convey specific legal advice. Any opinions expressed in this article do not necessarily reflect the views of FELLP Law, its partners, or its clients. Accordingly, do not act upon this information without seeking counsel from a licensed attorney. This blog is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Communicating with FELLP Law through this website by email, blog post, or otherwise, does not create an attorney-client relationship for any legal matter. Therefore, any communication or material you transmit to FELLP Law through this blog, whether by email, blog post or any other manner, will not be treated as confidential or proprietary. The information on this blog is published “AS IS” and is not guaranteed to be complete, accurate, and or up-to-date. FELLP Law makes no representations or warranties of any kind, express or implied, as to the operation or content of the site. FELLP Law expressly disclaims all other guarantees, warranties, conditions and representations of any kind, either express or implied, whether arising under any statute, law, commercial use or otherwise, including implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall FELLP Law or any of its partners, officers, employees, agents or affiliates be liable, directly or indirectly, under any theory of law (contract, tort, negligence or otherwise), to you or anyone else, for any claims, losses or damages, direct, indirect, special, incidental, punitive or consequential, resulting from or occasioned by the creation, use of or reliance on this site (including information and other content) or any third party websites or the information, resources or material accessed through any such websites. In some jurisdictions, the contents of this blog may be considered Attorney Advertising. If applicable, please note that prior results do not guarantee a similar outcome. Photographs are for dramatization purposes only and may include models. Likenesses do not necessarily imply current client, partnership or employee status.