BOI compliance reporting integration with CRM tools

The Financial Crimes Enforcement Network (FinCEN) has significantly updated its Beneficial Ownership Information (BOI) reporting requirements. As of an interim final rule issued on March 26, 2025, U.S. companies and U.S. persons are no longer required to report BOI.

The reporting obligation now primarily applies to certain foreign entities registered to do business in the U.S. that do not qualify for an exemption.Deadlines for Foreign Reporting Companies:Foreign reporting companies registered in the U.S. before March 26, 2025, must file their BOI report by April 25, 2025.Foreign reporting companies registered on or after March 26, 2025, have 30 calendar days after receiving notice of effective registration to file their initial BOI report.

Previous deadlines for domestic companies should be disregarded.Required BOI Elements:FinCEN requires a few pieces of information about the company and its beneficial owners, such as name, address, and date of birth for individuals.

Reporting companies may also provide a FinCEN identifier.Filing Channels and Technical Access:BOI reports must be filed electronically through FinCEN's secure BOI E-Filing system. FinCEN also supports third-party filing via an Application Programming Interface (API).

Third-party service providers can use either the E-Filing website or the API, and can submit multiple reports via API, receiving acknowledgements and transcripts. Technical API specifications are available upon request from FinCEN.Guidance for Third-Party Filers and Recordkeeping:While FinCEN does not mandate specific records for third-party service providers proving authorization, it recommends best practices.

These include obtaining written authorization, keeping a submission transcript, and maintaining documentation to demonstrate filing authority. Willfully filing false information can lead to penalties.Data Protection, Access, and Audit:FinCEN stores BOI securely in a centralized database with stringent Federal information security controls.

Access for authorized recipients is tightly controlled and subject to reporting and audit requirements. For CRM integration, this means treating BOI as highly sensitive Personally Identifiable Information (PII), requiring encryption at rest and in transit, restricted access via role-based controls, and comprehensive logging and auditing of access.Practical CRM Integration Patterns:To integrate BOI reporting into CRM systems, consider these steps:

Identify Reporting Companies

Tag CRM records by jurisdiction and registration type to identify entities subject to reporting.

Collect BOI Fields

During customer onboarding, gather necessary BOI data, including company-level information and beneficial owner details (name, DOB, address, identification method).

Design BOI Schema

Create a BOI schema within the CRM (e.g., company record linked to beneficial owner objects) that aligns with FinCEN's expected payload.

Implement Secure Storage

Encrypt PII, use role-based access controls to restrict UI visibility, and maintain a read-only history of BOI submissions.

Build Automation

Develop validation rules, integrate identity-document capture or reference a secure KYC provider, set up triggers for update deadlines, and create webhooks or scheduled jobs to prepare BOI e-file payloads.

Submission

Options include exporting batch files for manual upload to FinCEN's BOI E-Filing web UI, direct integration with the FinCEN API (requiring API specs from FinCEN), or using an authorized third-party filing partner that supports API submission.

Confirmations & Retention

Capture FinCEN submission transcripts/acknowledgements in the CRM and retain them according to legal and internal policies. Provide notifications to company contacts regarding submissions or required updates.

Audit & Monitoring

Log all changes to BOI data, maintain immutable submission records, and schedule periodic reviews and SOC-style controls.State-Specific Considerations for U.S. Businesses:BOI reporting is a federal requirement, not a state filing. However, state-level events, such as Secretary of State notices or business registration filings, often trigger the reporting timeline. CRM logic should capture these state registration events and link them to filing deadlines (e.g., the 30-day countdown for foreign registrants after March 26, 2025). It is crucial to monitor state Secretary of State communications for guidance or data that helps identify impacted entities. Always verify up-to-date requirements directly with FinCEN and relevant state notices.Overlap with KYC/AML:BOI data shares similarities with Know Your Customer (KYC) and Customer Due Diligence (CDD) data used by financial institutions. CRMs already collecting KYC data may be able to reuse many fields, but BOI reporting has distinct requirements, retention policies, and legal obligations. Coordination with legal and compliance counsel is essential.Legal & Operational Cautions:The regulatory landscape for BOI has evolved rapidly, notably with the March 2025 interim final rule. Companies must verify current requirements directly with FinCEN and seek legal counsel before relying on outdated guidance. It is also important to confirm if your entity qualifies for any exemptions.