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INTERIM FINAL RULES RELEASED BY FINCEN

NOTICE: THE TEEPLE HALL, LLP CTA PORTAL HAS CLOSED AND IS NO LONGER ACTIVE. PLEASE SEE BELOW FOR DETAILS.

On March 21, 2025, the U.S. Department of the Treasury released its interim final rules describing which entities are subject to CTA reporting and what information must be submitted. Among its notable points, U.S.-based reporting companies and beneficial owners are now exempt from CTA reporting requirements.

Given that the Teeple Hall, LLP CTA Portal was designed primarily to assist and facilitate U.S.-based companies with their CTA reporting obligations, and such obligations are no longer required, the CTA Portal has closed and is no longer in service.

Below are the key points of FinCEN's interim final rules, which should be reviewed, particularly if there is any connection to a foreign reporting company, defined in the CTA as “any entity that is: (A) a corporation, limited liability company, or other entity; (B) formed under the law of a foreign country; and (C) registered to do business in any State or tribal jurisdiction by the filing of a document with a secretary of state or any similar office under the law of a State or Indian tribe”:

  1. All domestic reporting companies and their beneficial owners are exempt from CTA reporting.
  2. Domestic reporting companies who have already submitted beneficial ownership information reports are not required to submit any further reports.
  3. Foreign reporting companies are required to submit beneficial ownership information reports related to the entity itself and any foreign persons who are considered beneficial owners of such entity.
  4. Foreign reporting companies are not required to submit the beneficial ownership information of any beneficial owner who is a U.S. person.
  5. Foreign reporting companies whose beneficial owners are all U.S. persons are exempt from reporting any beneficial owners.
  6. Foreign pooled investment vehicles are exempt from reporting any U.S. persons who exercise substantial control over the entity.
  7. The updated CTA reporting deadline for a foreign reporting company is 30 days from its registration or 30 days from March 21, 2025, for an existing foreign reporting company.

The interim final rules are open for public comment by the following methods:

  • Federal E-rulemaking Portal: https://www.regulations.gov, referencing Docket Number FINCEN-2025-0001, OMB control number 1506-0076, and RIN 1506-AB49.
  • Mail: Policy Division, Financial Crimes Enforcement Network, P.O. Box 39, Vienna, VA 22183. Refer to the same docket, control, and identification numbers.