Author Ownership Data (AOD): Comprehensive Insights You Require
In March 2025, the Financial Crimes Enforcement Network (FinCEN) announced changes to the Beneficial Ownership Information (BOI) reporting requirements, focusing the reporting on foreign entities doing business in the United States.
Key points:
- Domestic entities (U.S.-formed companies) and their beneficial owners are now exempt from BOI reporting, as of the interim final rule effective March 26, 2025. This means U.S. companies no longer have to submit beneficial ownership information to FinCEN.
- Foreign entities formed under the laws of a foreign country but registered to do business in a U.S. state or tribal jurisdiction remain subject to BOI reporting requirements.
These foreign entities must report beneficial owners who are non-U.S. persons. They are not required to report beneficial owners who are U.S. persons, nor must U.S. persons report their beneficial ownership of such entities.
For foreign entities already registered in the U.S. before March 26, 2025, the deadline to file BOI reports was April 25, 2025. For foreign entities registering to do business in the U.S. after March 26, 2025, the deadline is within 30 calendar days of registration to file the BOI report with FinCEN.
The BOI report is 4 pages long and has 51 questions. The last question in the report requests an image of an identifying document, such as a driver's license.
The new rule also provides foreign entities with the option to create a FinCEN ID to simplify the reporting process. No attorney or certified accountant is needed to file the BOI report, and there is no filing fee.
Foreign entities can file their BOI reports on the BOI E-Filing website. They can also sign up for FinCEN updates via email or text by clicking a link.
Violating BOI reporting requirements could result in up to two years of federal prison and a $10,000 fine. If a foreign company "willfully" ignores the BOI reporting rules, they may face a penalty of $500 a day (as of this writing, $591).
The Corporate Transparency Act (CTA) made beneficial ownership information reporting a requirement by law on January 1, 2021. The interim final rule was announced by FinCEN in March 2025, and comments on this rule were accepted until May 27, 2025, with finalization expected later in 2025.
These changes streamline the reporting burden and better target financial transparency efforts on foreign-owned businesses operating in the U.S. Sole proprietor authors in the United States are not impacted by BOI.
- Despite the exemption for domestic entities, foreign businesses registered to do finance or business in the United States are still required to report beneficial ownership information to FinCEN under the Beneficial Ownership Information (BOI) reporting requirements.
- Foreign entities conducting finance or business in the U.S. must adhere to the BOI reporting deadlines, with the deadline for entities already registered before March 26, 2025, being April 25, 2025, and for entities registering after that date, within 30 calendar days of registration.
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