Treasury Department and FinCEN Announce Drastic Limits on Enforcement of Corporate Transparency Act

In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against US citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. 

This bold announcement comes days after the Financial Crimes Enforcement Network (“FinCEN”) announced that it will not impose fines or penalties or otherwise take enforcement actions against companies for their failure to file a BOI report by the current March 21, 2025 deadline. 

Treasury Secretary Scott Bessent stated that this action is “part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.”

While this recent announcement signals a further softening of the government’s enforcement position, especially for US citizens and US companies, it implies that foreign companies and individuals could nevertheless still be subject to some of the BOI reporting rules and associated penalties. Despite these announcements paring back the enforcement of the BOI reporting rules, they do not repeal the federal statutes imposing the BOI reporting requirements, nor do they directly affect the numerous BOI-related court cases which are still pending.

Accordingly, companies with current reporting obligations will need to decide whether to file their BOI reports prior to the current March 21, 2025 deadline, or wait until the new proposed rules are published, given the prospect of the new rules not only impacting the filing deadlines but narrowing the scope of the rules to apply to foreign reporting companies only.

Those impacted should closely monitor the regulatory landscape for upcoming proposed rules which are expected by March 21, 2025. 

Our legal team is available to address any of your CTA questions or concerns. Please visit our CTA webpage for further information on the CTA and related developments.