Update as of December 4, 2024: The U.S. District Court for the Eastern District of Texas has suspended the implementation of the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) reporting requirements. Read more here: U.S. District Court Suspends Implementation of BOI Reporting Requirements

As we reported earlier this month in our blog, FINCEN Now Accepting Beneficial Ownership Information (BOI) Reports, January 1, 2024 marked the first day that FinCEN began accepting BOI reports. As of January 25, 2024, FinCEN has increased the civil monetary penalties for violating the BOI reporting rules. Here’s what you should know.

What is BOI Reporting?

Check out our blog, FINCEN Now Accepting Beneficial Ownership Information (BOI) Reports for the details.

Editor’s Note: As of March 1, 2024, members of the National Small Business Association (NSBA) are not subject to the Corporate Transparency Act (CTA) and therefore do not have any Beneficial Ownership Information (BOI) reporting obligations. Check out our blog, UPDATE: Corporate Transparency Act Ruled Unconstitutional, Here’s How BOI Reporting is Affected for the details.

What are the increased penalties?

Under prior rules, the penalties for willfully providing false or fraudulent information in a BOI report, or for willfully failing to file a complete or updated BOI report, were a $500-per-day fine up to $10,000 and imprisonment for up to two years – potentially both.

As of January 25, 2024, the penalties for reporting violations and unauthorized disclosure or use of BOI are increased to $591 per day.

If you need assistance to determine whether you have a BOI reporting requirement, we are advising our clients to work with their attorneys to make that determination and assist with the legal filing. There are also a number of corporate compliance service companies that can assist with the filing, for a reasonable fee. Additional information can be found at FINCEN’s FAQ page.

Questions? We can point you in the right direction. Contact us.