Corporate Transparency Act & FinCEN BOI Compliance in New York

Updated March 2025

Business owners in New York have been closely watching the Corporate Transparency Act (CTA) and its beneficial ownership reporting requirements. On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that significantly changes compliance obligations.

This rule is a game-changer for corporations, LLCs, and small business owners across New York.

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What Did FinCEN Change?

Under the new rule:

• U.S. entities are no longer considered reporting companies. Corporations, LLCs, and similar domestic business structures in New York are exempt from filing BOI reports.

• U.S. citizens and lawful residents are exempt as beneficial owners.

• Foreign entities registered to do business in the U.S. must still comply with BOI reporting unless they qualify for a specific exemption.

This means that, for now, most New York business owners no longer need to file FinCEN BOI reports under the CTA.

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Key Deadlines for Foreign Companies

• Foreign entities registered before March 26, 2025 must submit BOI reports by April 25, 2025.

• Foreign entities registering on or after March 26, 2025 must file their BOI report within 30 days of registration.

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Why the Sudden Change?

FinCEN explained that the exemption serves the public interest and no longer advances national security or law enforcement goals in the same way. This shift follows:

• Ongoing court challenges to the CTA.

• A change in presidential administrations.

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What New York Business Owners Need to Know

If you operate a corporation, LLC, or partnership in New York, here’s what this update means for you:

• No BOI reporting required (for now). Domestic companies in New York are exempt under the interim rule.

• Foreign companies remain covered. Only non-U.S. entities doing business here still need to report.

• Future changes are possible. The rule is interim and open to revision. A final rule is expected later in 2025.

• Private contracts may still apply. Some lenders and investors may continue to require CTA-related compliance.

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How Our Law Firm Can Help

At our firm, we stay ahead of FinCEN BOI compliance updates and guide New York businesses through these evolving rules. Whether you’re a small business owner, real estate investor, or managing multiple entities, we provide:

• Legal advice on Corporate Transparency Act requirements.

• Guidance for foreign entities still required to file.

• Strategies for businesses with FinCEN Identifiers that may need updating or deactivation.

• Ongoing monitoring of CTA litigation and regulatory changes.

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Schedule a Consultation

Even though U.S. entities are exempt today, the Corporate Transparency Act remains an area of uncertainty. Regulations can shift quickly, and businesses that ignore compliance risk future penalties.

If you want clarity on how the CTA and beneficial ownership rules affect your New York business, contact our office today.

We’ll help you stay compliant with FinCEN BOI rules while protecting your business.