FinCEN Narrows CTA Reporting Requirements

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) released an Interim Final Rule (the Interim Rule), which served to “narrow” the existing beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (CTA or the Act). The Interim Rule, which appears to have immediate effect, (a) exempts from the Act's coverage all entities previously defined as “domestic reporting companies,” (b) limits the CTA reporting requirements to only “foreign reporting companies,” and (c) removes any requirement that U.S. persons need to submit, update, or correct BOI at all. In addition, it revises the reporting requirements for foreign pooled investment vehicles, which will not need to report the BOI of U.S. persons who exercise substantial control over the entity.