BOI documentation support for founders with complex structures

As of March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) has removed the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act. This means that all entities created in the United States, including corporations and limited liability companies (LLCs), are now exempt from BOI reporting to FinCEN. The regulatory definition of a "reporting company" has been revised to include only entities formed under the law of a foreign country that have registered to do business in any U.S. State or Tribal jurisdiction. These foreign entities, if they do not qualify for an exemption, must still report their BOI to FinCEN under new deadlines. For these foreign reporting companies, the reporting typically involves providing the name, birthdate, residential address, and a unique identifying number from an acceptable identification document for each beneficial owner. A beneficial owner is an individual who either directly or indirectly exercises substantial control over the company or owns or controls at least 25% of its ownership interests. For foreign entities with complex, multi-layered ownership structures that are still subject to BOI reporting, compliance can be challenging. Practical recommendations include conducting a thorough ownership analysis, working with legal and compliance experts, leveraging technology for ownership tracking, and implementing ongoing compliance monitoring.