A U.S. District Court for the Eastern District of Texas has issued a preliminary injunction that prevents the Financial Crimes Enforcement Network (“FinCEN”) from enforcing its Beneficial Ownership Information (“BOI”) reporting requirements. For reporting companies in existence before January 1, 2024, a BOI report filing would have been due by January 1, 2025. Reporting companies first created during calendar year 2024 were required to file a BOI report within 90 days of the reporting company’s formation.
In short, BOI report filing obligations have been temporarily blocked by the Court.
Since the Court’s decision takes the form of a preliminary injunction, this is unfortunately not the end of the story. FinCEN is expected to appeal the decision, and time will tell whether BOI reporting requirements will resurface in the future.
For now, however, FinCEN cannot enforce BOI reporting requirements against any reporting company or beneficial owner nationwide.
To read more about the decision, please refer to this press release.