BOI Enforcement by FinCEN Still on Hold

Due to a recent federal court order, reporting companies are not currently required to file beneficial ownership information (BOI) with the Financial Crimes Enforcement Network (FinCEN) and are not subject to liability while the order remains in place. 

Key Developments:

• On January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland). 

• A separate nationwide order, issued by a different federal judge in Texas (Smith v. U.S. Department of Treasury), still remains in place despite the Supreme Court’s ruling.
  
• Reporting companies may continue to voluntarily submit BOI with FinCEN.

Learn more about the details of this announcement at FinCEN BOI. 

Aprio is closely monitoring the situation and will provide updates as new information unfolds. 

Contact your Aprio advisor with any questions about how this alert impacts you.