FinCEN BOI compliance specialist

FinCEN

BOI compliance specialist — practical guidance for US businesses Introduction If you’re an LLC founder, business owner, or counsel helping clients navigate BOI compliance, the Corporate Transparency Act and FinCEN’s BOI reporting regime raise important legal, operational, and data‑security tasks.

This post explains who must report now after FinCEN’s 2025 interim final rule, what information to collect, how to file, state‑level interactions, enforcement risks, and step‑by‑step workflows and templates a BOI compliance specialist should use. 1) Who must (currently) file a BOI report? - After FinCEN’s March 26, 2025 interim final rule, the regulatory term “reporting company” applies to foreign entities formed under the law of a foreign country that have registered to do business in any U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office.

Domestic entities formed in the U.S. are, by the IFR, exempt from BOI reporting. Note: this is the controlling change and may be finalized/updated by FinCEN rulemaking; always confirm on FinCEN.gov/BOI.

Title: FinCEN BOI compliance specialist — practical guidance for US businesses Introduction If you’re an LLC founder, business owner, or counsel helping clients navigate BOI compliance, the Corporate Transparency Act and FinCEN’s BOI reporting regime raise important legal, operational, and data‑security tasks.

This post explains who must report now after FinCEN’s 2025 interim final rule, what information to collect, how to file, state‑level interactions, enforcement risks, and step‑by‑step workflows and templates a BOI compliance specialist should use. 1) Who must (currently) file a BOI report? - After FinCEN’s March 26, 2025 interim final rule, the regulatory term “reporting company” applies to foreign entities formed under the law of a foreign country that have registered to do business in any U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office.

Domestic entities formed in the U.S. are, by the IFR, exempt from BOI reporting. Note: this is the controlling change and may be finalized/updated by FinCEN rulemaking; always confirm on FinCEN.gov/BOI.

Key exemptions (high level) - FinCEN’s rule and guidance list statutory exemptions (e.g., many regulated entities, large operating companies, tax‑exempt entities, certain public utilities and financial institutions). Confirm each client against the list in FinCEN’s Small Entity Compliance Guide and the regulations.

What information must be reported (data elements) - Reporting company data (initial report)

full legal name, any trade/DBA name, complete current address, jurisdiction of formation/first U.S. registration (for foreign entities), and taxpayer identification (EIN or foreign tax ID where applicable). - For each beneficial owner and any company applicant (if required): full legal name, date of birth, current residential address, unique identifying number from acceptable documents (non‑expired U.S. passport; state/local/tribal ID; state driver’s license; or, only if none of the prior are available, foreign passport), and a digital image of the document used for the identifying number. A FinCEN ID may be used in place of supplying those data elements. - Data format details: unique IDs entered as plain text without formatting (no hyphens/spaces). Image formats supported: JPG/JPEG, PNG, PDF; max file size 4 MB.

How to file with FinCEN (options & technical points) - File using FinCEN’s BOI E‑Filing portal

https://boiefiling.fincen.gov . Filing methods: (a) Online web form (real‑time; cannot be saved mid‑session), (b) Upload final PDF BOIR and submit online, or (c) System‑to‑system BOIR API for automated filings (used by third‑party providers or in‑house automation). - The person who submits must provide name and email; submitter receives confirmation and the FinCEN ID (if requested). For web filings, assemble all required information and identity document images before starting.

Deadlines and triggers (current from IFR and FinCEN guidance) - Under the March 26, 2025 interim final rule

foreign reporting companies registered to do business in the U.S. before March 26, 2025 were given until April 25, 2025 to file; foreign reporting companies registering on/after March 26, 2025 generally have 30 calendar days from notice that registration is effective to file initial BOIRs. - Update/correction windows: normally 30 days to update after a change, and 30 days to correct inaccuracies after discovery; consult FinCEN guidance for limited safe harbors and enforcement guidance. - Practical implication: watch the date the state files/acknowledges a foreign entity’s registration — that public or actual notice starts the countdown for filing. 6) Penalties and enforcement - Willfully failing to report, willfully providing false or fraudulent BOI, or willfully causing a company not to file may result in civil penalties (up to $500 per day) and criminal penalties (up to 2 years imprisonment and/or fines up to $10,000). Senior officers can be held accountable.

State interactions and registered agent considerations - State Secretaries of State do not administer federal BOI filings; they typically direct businesses to FinCEN. However, state filings (formation/registration) and a state’s public notice can trigger the FinCEN filing deadline. - What to list as the company’s address

FinCEN requires a complete current address. Some entities use registered agent addresses as principal places of business; verify that the address is accurate and consistent with BOIR requirements. A change in address can trigger an updated BOI report when it affects information previously submitted.

Practical workflows and checklists for a BOI compliance specialist A. Client intake checklist (minimum information to collect upfront)

- Entity legal name, trade name/DBA, jurisdiction and date of formation, state registration documents, EIN/tax ID (or foreign tax ID), current principal place of business (address to use in BOIR), list of all owners/members/shareholders and managers/officers, for each individual: full legal name, date of birth, residential address, acceptable ID type and number, digital image of the ID (JPG/PNG/PDF,