Compliance · FinCEN
FinCEN BOI: where the reporting obligation stands
The Corporate Transparency Act created an obligation to report beneficial ownership information (BOI) to FinCEN, a bureau of the US Treasury. Since the interim final rule published on March 26, 2025, entities formed in the United States are exempt. This page describes the rule in force, its sources, and what Billionnaire Online provides: monitoring and an exemption attestation, never a filing.
The Corporate Transparency Act and BOI reporting
The Corporate Transparency Act (2021) tasked FinCEN with collecting the identity of the beneficial owners of corporations and LLCs. Collection began on January 1, 2024 and originally covered both domestic and foreign reporting companies.
The interim final rule of March 26, 2025
On March 26, 2025, FinCEN published an interim final rule that redefines the "reporting company": only entities formed under the law of a foreign country and registered to do business in a US state remain subject to reporting.
In FinCEN's words, all entities created in the United States, including those previously known as "domestic reporting companies", and their beneficial owners are exempt from the requirement to report. FinCEN stated that it applies these exemptions as of March 21, 2025 and will not enforce penalties against domestic entities.
What this means for a Wyoming, New Mexico or Delaware LLC
An LLC formed under the law of a US state is a domestic entity within the meaning of this rule, whatever the nationality or residence of its members. The test is where the entity was formed, not who owns it.
As the rule stands, such an LLC has no BOI report to file. Billionnaire Online therefore files no BOI report and charges for none.
Why monitoring
The rule of March 26, 2025 is interim: FinCEN opened a comment period and announced its intention to issue a final rule. The scope of the exemption may therefore change.
Billionnaire Online's monitoring is an automated weekly check of FinCEN's official BOI reporting page, with an alert sent to the client as soon as a change is detected. Should the obligation be reinstated for domestic entities, you would be informed and you would decide what to do next. We file nothing on our own initiative.
What the exemption attestation contains
The attestation is a dated document, issued per file, which states the entity's name, its state and date of formation, the basis of the exemption (the definition of "reporting company" as amended by the interim final rule of March 26, 2025), the date of the last check of FinCEN's page and the fingerprint of the version checked.
It documents an administrative situation at a given date. It is not an opinion and does not prejudge future rules.
Frequently asked questions
Does my LLC have to file a BOI report with FinCEN?
Under the interim final rule of March 26, 2025, an entity formed in the United States is exempt. A Wyoming, New Mexico or Delaware LLC therefore has no BOI report to file.
Is this final?
No. It is an interim final rule. FinCEN has announced a final rule to come. That is the reason for the monitoring offered.
I am not a US resident: does that change anything?
No. The rule's test is where the entity was formed, not the nationality or residence of its members.
What does Billionnaire Online provide on this point?
Weekly monitoring of FinCEN's official page with an alert on any change, and a dated exemption attestation per file. No BOI filing is sold or made.
Which entities remain subject to reporting?
Entities formed under the law of a foreign country and registered to do business in a US state, subject to the exemptions provided by the rule.
FinCEN monitoring is an option on every file.
Order the filingOfficial sources
Billionnaire Online is an administrative filing service. We do not act as attorneys, accountants or tax advisers. The information on this page describes an administrative procedure and is not an opinion on your situation. Choosing a state or a structure is your decision and, where needed, that of licensed professionals.