On February 18, 2025, in the wake of ongoing litigation in the Smith case, the Financial Crimes Enforcement Network (FinCEN) issued a notice that provided a new beneficial ownership reporting deadline under the Corporate Transparency Act: March 21, 2025. However, in a February 27, 2025, press release, FinCEN stated that it will not impose fines or penalties on companies that fail to file or update their beneficial ownership information (BOI) reports by the current deadlines. Per the press release, this pause in enforcement will remain in effect until an interim final rule is enacted, which is expected by the new March 21, 2025, deadline and will extend the BOI reporting deadlines.
Subsequently, on March 2, 2025, the Treasury Department announced that it will suspend enforcement of penalties associated with BOI reporting under both existing deadlines and future rule changes. Furthermore, a proposed rulemaking seeks to limit the scope of the rule to foreign reporting companies only.