In this year so far, we have published several posts regarding the Beneficial Ownership Information (BOI) enforced by Financial Crimes Enforcement Network (FinCen). The latest BOI related post titled ” When in doubt, keep filing BOI reports” from March 2024 expressed our recommendation to keep filing the BOI as the unconstitutional declaration by the U.S. District Court, N.D. of Alabama applied only to the plaintiffs. From sharing the timeline of communication to other agencies and foreign governments up to 2025, the FinCen considers that the BOI will still be applicable to all entities (favorable appeal and this program considered constitutional).
From the article in the Journal of Accountancy, more details on the timeline is provided “…In between, in summer of 2024, access will be granted to Treasury offices and other federal agencies engaged in law enforcement and national security activities that already have memoranda of understanding for access to BSA information and in the fall of 2024 to additional federal agencies engaged in law enforcement, national security, and intelligence activities.
In the winter of 2024, FinCEN will extend access to intermediary federal agencies in connection with foreign government requests. Finally, in the spring of 2025, access will be extended to financial institutions subject to customer due diligence requirements under applicable law and their supervisors.”
Updated FAQs provide details on phase-in timing of BOI access
