BOI compliance handbooks for founders

Regulatory status (concise): explain the interim final rule (March 26, 2025) that exempts domestic reporting companies from BOI reporting to FinCEN and preserves reporting obligations for certain foreign reporting companies, plus the updated deadlines and the ongoing rulemaking/comment period.

Who this affects: clear decision flow for founders: (

Regulatory status (concise): explain the interim final rule (March 26, 2025) that exempts domestic reporting companies from BOI reporting to FinCEN and preserves reporting obligations for certain foreign reporting companies, plus the updated deadlines and the ongoing rulemaking/comment period.

Who this affects: clear decision flow for founders: (

Is the entity a U.S.-formed company (domestic)? If yes — currently exempt from filing BOI to FinCEN but still monitor developments; (

If the entity is a foreign entity registered to do business in the U.S., it likely must file — check exemptions; (

Special cases

pooled investment vehicles, trusts, entities with non-U.S. owners — discuss special reporting rules. Key definitions (with plain-language guidance): reporting company, beneficial owner (ownership >25% OR substantial control), company applicant (for entities created/registered on/after Jan 1, 2024), U.S. person vs. non-U.S. person, exempt entities. Exemptions overview: explain that 24 specific statutory/regulatory exemptions exist (examples: banks/credit unions/insured depository institutions, certain tax-exempt entities, large operating companies), and direct readers to FinCEN resources to confirm applicability for their entity. Practical compliance checklist for founders (step-by-step):

Confirm entity formation jurisdiction and registration status (domestic vs foreign reporting company);

Determine whether any statutory/regulatory exemptions apply;

Identify beneficial owners (collect legal name, DOB, address, SSN/ITIN or passport for non-U.S. persons, and a copy/image of an acceptable photo ID where required) and company applicants when applicable;

Create a secure central record (encrypted internal files) with collected BOI documents, chain-of-custody notes, and retention policy;

Appoint a compliance owner (founder or counsel) and document internal policies for BOI collection/updates and third-party requests;

If required to report, create a FinCEN ID and use the BOI E-Filing System (boiefiling.fincen.gov) to submit initial reports and timely updates/corrections (typically within 30 days of a change, per current guidance for foreign reporting companies);

Train staff and advisers (registered agents, accountants, lawyers) on BOI processes; and

Reassess and update the handbook when FinCEN issues a final rule or other changes occur. Templates & sample language

offer template checklists, email scripts to request BOI from owners, internal policy summary, and a short sample privacy/access control clause for BOI records. Penalties & enforcement: summarize historical penalties available under CTA (civil and criminal) but note that FinCEN has stated it is not enforcing BOI penalties against U.S. domestic companies and U.S. persons under the March 2025 interim final rule; nevertheless prudent recordkeeping and readiness are recommended. State-specific note: The BOI reporting requirement is a federal (FinCEN/CTA) requirement. Because state-level rules can affect formation/registration timing and registered-agent processes, founders should confirm state filing/registration details with the Secretary of State’s office—but FinCEN’s interim final rule is the controlling federal position on BOI reporting scope. If a company is a foreign entity registered in a U.S. state, FinCEN might consider it a reporting company — founders must check both the entity’s formation jurisdiction and registration status. Ongoing monitoring & next steps: link to FinCEN BOI resources, BOI E-Filing system, Federal Register docket for the interim final rule, and counsel resources. Encourage subscribing to FinCEN updates and consulting counsel when in doubt.