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.
Latest News
D.C. Circuit Rejects DOE’s Use of Emergency Authority to Prevent Coal Plant Retirement
The D.C. Circuit vacated the Department of Energy’s order compelling continued operation of Michigan’s J.H. Campbell coal plant under DOE’s emergency authority, finding that Section 202(c) is a narrow, last-resort power reserved for immediate grid-reliability emergencies, not longer-term resource planning.
New BIS “Affiliates Rule” Compliance Date is November 10 Unless Suspended by U.S.-China Truce
A new party screening requirement will soon impact compliance of international dealings unless the U.S. Department of Commerce’s Bureau of Industry and Securities (“BIS”) issues a second extension of its effective date.
California’s New AI Law: What Legal Departments and Outside Counsel Need to Know
Newly enacted California Senate Bill 574 regulates how attorneys use generative AI by amending the California Code of Civil Procedure and requiring attorneys to personally verify every citation, whether sourced from AI or otherwise. It also holds law firms jointly responsible for sanctionable violations by their attorneys. The bill added a new section to the California Code of Civil Procedure (§ 1282.1), barring arbitrators from delegating their decision-making to generative AI.
Beyond Allulose: What Comes Next in Sugar-Related False Advertising Litigation?
The Franco decision has given plaintiffs a potential roadmap for challenging “Sugar Free,” “Zero Sugar” and similar claims when FDA guidance and existing regulations do not fully align.