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Client Alert: Corporate Transparency Act – Yes, it’s Back, but no Fines or Penalties for Now

By Zachary M. Chupak and Julie K. O’Neill • February 28, 2025

On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any entities based on failure to file or update beneficial ownership information reports.

Pursuant to this new guidance, the deadline of March 21, 2025, to file beneficial ownership information reports is now the deadline for FinCEN to issue to an interim final rule that extends BOI reporting deadlines. For now, there is no deadline to file beneficial ownership information reports.

Employers and companies with questions about how to comply with the CTA should consult their Bowditch attorney. We will assume you are handling these matters on your own unless you request assistance from your Bowditch attorney in writing.

Categorized: Client Alerts, Publications

Tagged In: business owners, FinCen, Beneficial Ownership Information

About the Authors

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Partner

Julie K. O’Neill

Julie O’Neill focuses her practice on business, corporate and securities law, and counseling individuals and entities at all stages of the corporate life cycle on a wide variety of sophisticated transactions in the U.S., Canada, and abroad. Julie regularly handles:

Entity selection and formation
Private placements including angel and venture capital equity financings
Limited liability company operating agreements and shareholders’ agreements
Mergers and acquisitions
Recapitalizations
Private equity fund formation
Secured transactions
Employment issues and partnership disputes
Licensing arrangements and general contract matters
Trademark and copyright registrations

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Associate

Zachary M. Chupak

Zachary Chupak is an Associate in the Estate, Financial & Tax Planning Practice Area. He assists high-net worth individuals and families in need of asset protection, business succession planning and gift and estate tax strategies. Multi-generational and blended families seek Zach’s assistance with estate planning, estate administration, probate and tax litigation, and family office needs. 

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