Is FinCen BOI “Fini”?

We are interrupting our M&A series to provide an important update related to the BOI reporting requirements.  Last Friday, the Department of Treasury issued an interim final rule which further clarified it will not enforce BOI reporting against US Citizens or domestic reporting companies or their beneficial owners.  They will, however, still require foreign reporting companies to report under BOI.  For US citizens and US based companies, it appears that FinCen’s BOI requirement is “fini”.  Given the new administration’s recent moves in this regard, we don’t see much in the way of legal action moving forward on this update.  

Interim Final Rule Press Release