Update: FinCEN’s Interim Final Rule for BOI Reporting Requirements
04.09.2025 Written by: Henningson & Snoxell, Ltd.

Financial Crimes Enforcement Network (FinCEN) announced its interim final ruling regarding the Beneficial Ownership Information (BOI) reporting requirements Friday evening, March 21, 2025. The interim final ruling provides that entities created in the U.S., and their beneficial owners, are exempt from the BOI reporting requirement. Foreign entities, i.e., entities formed outside of the U.S., are still required to file their BOI report within the applicable timeframe, but U.S. persons who are beneficial owners of a foreign entity are not required to be reported as beneficial owners.
This means that entities formed in the state of Minnesota or any other U.S. state are exempt from filing the initial BOI report and no longer have the continuing obligation to file updated BOI reports. As with many of the BOI updates to this point, this is subject to changes that may occur in the final ruling.
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