On March 21, 2025, the Treasury Department announced that the Financial Crimes Enforcement Network would exempt domestic reporting companies and U.S. persons from the Corporate Transparency Act's beneficial-ownership reporting requirements. ¹ The interim final rule, published as 90 FR 13688 on March 26, 2025, was effective immediately. ² The compliance work many of us spent 2024 building did not disappear, it migrated.

The single sentence that matters, from the rule itself: "all entities created in the United States, including those previously known as 'domestic reporting companies', and their beneficial owners will be exempt from the requirement to report BOI to FinCEN." ³ Roughly 33 million U.S. entities that had been preparing for the original January 1, 2025 deadline are now outside the rule's scope.

What remains, and what's emerging at the state level, is the more interesting story.

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