Key Information on BOI Reporting Requirements
- Effective January 1, 2024, all U.S. and foreign companies formed in or registered with any of the 50 states must comply with new BOI reporting requirements set forth by the Financial Crimes Enforcement Network (FinCEN). This includes providing detailed information about the entity, its beneficial owners, and, in certain cases, its company applicants.
- Who Must Report?
Certain types of entities are required to submit Beneficial Ownership Information Reports (BOIRs) to FinCEN, certifying that the information provided is true, correct, and complete.
- When Are Reports Due?
• Existing Companies: If a reporting company existed before January 1, 2024, its initial BOIR is due by January 1, 2025.
• New Companies: Companies created or registered between January 1, 2024, and January 1, 2025, must file their initial BOIR within 90 days of receiving notice of their effective creation or registration.
• After January 1, 2025: New entities must file within 30 days of their effective creation or registration.
If there are any changes to the required information or inaccuracies identified in a filed BOIR, the company must file an updated report within 30 days of the change or becoming aware of the inaccuracy.
Required Information for BOIR Submission
To complete the BOIR, the following details about each beneficial owner must be included:
• Full legal name
• Date of birth
• Complete current address
• Unique identifying number and issuing jurisdiction from one of the following non-expired documents:
o U.S. passport
o State or local government-issued ID
o State-issued driver’s license
o Foreign passport (if none of the above are available)
o An image of the document used to obtain the unique identifying number
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