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Reporting Update – Beneficial Ownership Information Report (BOIR) Requirements Likely Delayed to March 2025

31
DEC
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Latest Court Decision on the Corporate Transparency Act (CTA) Also Brings Registration Issue to New Congress


Following an earlier go-ahead filing requirement determination, last week the Merit Appeals Panel for the Fifth Circuit decided to put the nationwide BOIR “pause” back into place, while the litigation moves through the legal process.


The same panel is scheduled to hear appeals arguments on March 25th, 2025. At this hearing, the Panel will determine whether the registration pause should remain in place until the broader case is again heard by the full court. 


Absent any new action, the business requirement to register with the Financial Crimes Enforcement Network (FinCEN) will remain paused until the end of March. FinCEN continues to post updates on the BOIR at their microsite, which may be found here.


IAM will continue to follow the court processes, any action in the new Congress on this requirement, and will update members with additional information as it comes in. If you have questions on the BOI requirements in the interim, please reach out to Bryan Vickers, with IAM’s Legislative and Regulatory team, bvickers@pacellp.com, 703-403-2882.