CTA Madness…. continues

By: Amanda Messa, General Counsel, LEMOINE 

  It’s probably only fitting that as the first round of March Madness was beginning late last week so was another round of CTA Madness – although I think most of us will find the latest update to be a better play by the government. 

   According to the most recent posting on FinCEN’s website, pursuant to an interim final rule released on March 21, 2025, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners are now exempt from the requirement to report beneficial ownership information (BOI) to FinCEN.  

  Existing foreign companies that must report their beneficial ownership information have at least an additional 30 days from the date of publication of the interim final rule.  A link to the interim rule can be found on FinCEN’s website:

 https://fincen.gov/sites/default/files/federal_register_notices/2025-03-21/CTAIFR3-21-25-FINAL508.pdf

  FinCEN is accepting comments on the interim final rule and expects to finalize the rule this year. 

Hopefully this update will free up at least a little of your time to catch some of the exciting basketball games that are sure to occur over the next few weeks!