BOI reporting for founders with multiple geographic teams

FinCEN's Interim Final Rule (IFR), effective March 26, 2025, significantly changes Beneficial Ownership Information (BOI) reporting. U.S.-formed entities and U.S. persons are now exempt from FinCEN BOI reporting requirements.

However, foreign entities registered to do business in the U.S. still have obligations. If your foreign entity registered before March 26, 2025, file your BOI report by April 25, 2025.

If registered on or after March 26, 2025, file within 30 calendar days of registration (or 30 days after the IFR publication date, whichever is later). A beneficial owner is an individual with substantial control or at least 25% ownership.

Collect required identifying information (name, DOB, residential address, ID number, and an image of the ID) for all beneficial owners. Use the FinCEN BOI E-Filing system for submissions and update reports within 30 days of any changes.

Even if exempt, maintaining internal BOI records is a best practice. Always check for state-specific reporting requirements, as they are separate from FinCEN obligations.

FinCEN's Interim Final Rule (IFR), effective March 26, 2025, significantly changes Beneficial Ownership Information (BOI) reporting. U.S.-formed entities and U.S. persons are now exempt from FinCEN BOI reporting requirements.

However, foreign entities registered to do business in the U.S. still have obligations. If your foreign entity registered before March 26, 2025, file your BOI report by April 25, 2025.

If registered on or after March 26, 2025, file within 30 calendar days of registration (or 30 days after the IFR publication date, whichever is later). A beneficial owner is an individual with substantial control or at least 25% ownership.

Collect required identifying information (name, DOB, residential address, ID number, and an image of the ID) for all beneficial owners. Use the FinCEN BOI E-Filing system for submissions and update reports within 30 days of any changes.

Even if exempt, maintaining internal BOI records is a best practice. Always check for state-specific reporting requirements, as they are separate from FinCEN obligations.