Corporate Transparency Law: Navigating the latest developments


The last months have brought so many changes to the Corporate Transparency Law (CTA) that it is difficult not to have cervical whip. With all the turns of the plot and flip flops in the courtroom, this saga feels like seeing a document. While the rest of the world remains up to date with the Kardashians, it is possible that you want to keep up with the CTA, since the reality of this landscape is still evolving.

Is the United States national companies expected to submit a BOI report?

No, national companies in the United States and US citizens do not need to present the BOI report based on an interim ruling. However, certain companies must still do it, as discussed in more detail below. The provisional ruling is provisional and can only be trusted that the courts issue a final ruling, which is expected to be available for the public at the end of 2025.

Updates on the requirements and deadlines of BOI reports (Source: FINCEN)

What is the CTA?

The CTA was established to dissuade the use of anonymous ghost companies for money laundering, tax evasion and other illicit purposes. It requires specific entities to inform your BOI to Finnn. From the most recent pronouncement, this information is consolidated in a data deposit only for foreign entities or individuals who possess or control companies that operate within the United States.

Finnn is an office within the United States Treasury Department that helps protect the integrity of the United States financial system. FINCEN has the task of investigating financial crimes through the collection and analysis of financial data. It manages the regulatory compliance with financial institutions and helps the application of the law by sharing the compiled financial data.

Who should comply with the CTA?

According to the previous legislation of CTA, many small companies that operate within the USs would have been subject to onerous reports requirements. According to Finn's most recent announcement, only entities defined as “foreign reporting companies” must complete BOI reports.

A foreign report company is defined as any corporation, limited liability company (LLC) or another similar entity that is

  1. Formed under the laws of a foreign country; and
  2. Registered to do business in the United States.

Although the United States Treasury Department announced that it would no longer apply the beneficial property of the CTA for national companies, the following is applied:

  • The foreign entities registered to do business in the USA. Before March 21, 2025, they must submit Boi reports no later than 30 days from that date.
  • The foreign entities registered to do business in the US.

Penalties for breach

Entities that do not meet the reports of CTA reports may face significant sanctions.

  • Civil sanctions: Up to $ 592 per day for each day the violation continues.
  • Criminal sanctions: Up to $ 10,000 and prison for up to two years for intentional violations.

Frequent questions (frequent questions)

Are the small reports of BOI reports under the CTA?

Yes. Based on the legislation at the time of this publication, the United States property and operation companies (large or small) do not need to submit beneficial property information reports.

Who needs to submit CTA reports?

Foreign companies operating in the USA must submit Boi reports under the CTA.

How is a BOI report presented?

Boi reports are presented at Boir.org. The reports of reports shown on the website can take time to reflect recent legislative updates.

How often should the presentations be updated?

The entities must update their BOI reports within 30 days of any change in the informed information to ensure that FINCEN records remain precise.

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