Client Alerts & Insights

Treasury Department Ends Domestic Enforcement of BOI Reporting Requirements Under the CTA

March 5, 2025

In our most recent alert on the Corporate Transparency Act’s (CTA) ever-changing beneficial ownership information (BOI) reporting requirements, we reported that while FinCEN set a new mandatory reporting requirement deadline of March 21, 2025 for most businesses, the agency would not issue fines or penalties against any company for failure to file or update BOI reports by that deadline, until a forthcoming interim final rule became effective.

On March 2, 2025, however, the Treasury Department announced that it will no longer enforce BOI reporting requirements on U.S. citizens or domestic companies. The forthcoming rule change will narrow the reporting requirements’ applicability to foreign reporting companies only. 

Companies should continue working with knowledgeable counsel to comply with BOI reporting requirements. If you have questions regarding the CTA or the impact of the multiple ongoing cases, the White Collar and Corporate & Securities Practice Groups at Benesch are here to help.

Marisa T. Darden at mdarden@beneschlaw.com or 216.363.4440.

Robert J. Kolansky at rkolansky@beneschlaw.com or 216.363.4575.

Jennifer L. Stapleton at jstapleton@beneschlaw.com or 216.363.4428.

Connie A. Porter at cporter@beneschlaw.com or 216.363.4433.

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On May 28, 2026, the U.S. Supreme Court issued a unanimous decision in Flowers Foods, Inc. v. Brock, expanding reach of the Federal Arbitration Act’s (“FAA”) Section 1 exemption for transportation workers engaged in interstate commerce. The Court held that a worker who transports goods on an intrastate leg of an interstate journey can qualify for Section 1’s exemption without crossing state lines or interacting with vehicles that do. This decision has significant implications for motor carriers and transportation providers that rely on arbitration agreements to resolve disputes with independent contractors and employee drivers.