New Federal Reporting Requirement for Beneficial Ownership Information (BOI)
Effective January 1, 2024, many companies in the United States need to report to the Financial Crimes Enforcement Network (FinCEN) information about their beneficial owners. Beneficial owners are the individuals who ultimately own or control the company. FinCEN is a bureau of the U.S. Department of the Treasury. If your company was created or registered prior to January 1, 2024, you have until January 1, 2025 to report Beneficial Ownership Information or BOI.
Companies required to report are called reporting companies. Your company may be a reporting company and need to report information about its beneficial owners if your company is:
1. A corporation, a limited liability company (LLC), or was otherwise created in the United States by filing a document with a secretary of state or any similar office under the law of a state or Indian tribe; or
2. A foreign company and was registered to do business in any U.S. state or Indian tribe by such a filing.
There are twenty-three types of entities that are exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies, nonprofits, and certain large operating companies. Large operating companies include U.S. located entities with more than $5,000,000 in gross receipts or sales and more than 20 full time employees. Subsidiaries of large operating companies and nonprofits are also exempt from the reporting requirements.
Further explanations of the information to be reported and detailed explanation of exempt entities may be found in the Small Entity Compliance Guide on the FinCEN website.
If your company was created or registered on or after January 1, 2024, and before January 1, 2025 and is not exempt from the reporting requirement, you must report BOI within 90 calendar days after receiving actual or public notice that your company’s creation or registration is effective, whichever is earlier. Companies created after January 1, 2025 will have 30 calendar days to report BOI. Any updates or corrections to beneficial ownership information that you previously filed with FinCEN must be submitted within 30 days.
As specified in the Corporate Transparency Act, a person or company that willfully violates the BOI reporting requirements may be subject to civil penalties of up to $500 for each day that the violation continues. That person may also be subject to criminal penalties of up to two years imprisonment and a fine of up to $10,000.
Reporting companies will have to report beneficial ownership information electronically through FinCEN’s website:
Other important information can be found on the FinCEN website at
Meadows Urquhart is gathering information and working through process development on this new requirement. We will make additional information available at a future date. In the meantime, please do not hesitate to reach out to us with questions. You may also desire to contact your attorney for additional information.
Also, please stay diligent of recent fraudulent attempts to solicit information. FinCEN is aware of recent fraudulent solicitations and posted this information:
“The fraudulent correspondence may be titled “Important Compliance Notice” and asks the recipient to click on a URL or to scan a QR code. Those e-mails or letters are fraudulent. FinCEN does not send unsolicited requests. Please do not respond to these fraudulent messages, or click on any links or scan any QR codes within them.”