In the on again, off again series of statements from FinCEN regarding the Corporate Transparency Act, it appears that enforcement is off again, and could be indefinitely. With respect to the BOI reporting requirements under the Act, FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update their BOI reports by the current deadlines. No fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.

FinCEN indicates that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect

Further, not only will the federal government not impose penalties or fines to entities that fail to file or update a BOI report under existing deadlines, it announced that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect. The Treasury Department will issue a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only.

*** The foregoing is a broad analysis provided for informational purposes only and does not represent legal advice for any specific client or their situation.  As a result, it may not be relied upon as legal advice.  If you need legal advice, you must contact our office directly regarding your specific situation. ***