Compliance Briefing — August 12, 2025

Executive briefing: FinCEN’s beneficial ownership reporting regime took effect on 1 January 2024. As of August 2025, reporting companies have moved beyond initial filings and must demonstrate mature change management so that updates on beneficial owners or company applicants reach FinCEN within 30 calendar days of knowledge or public record changes.

Key compliance checkpoints

• Trigger inventory. Maintain a checklist of events—equity transfers, senior officer changes, re-registrations—that require BOI updates and map each trigger to responsible teams.
• Documentation standards. Capture identity documents, residential addresses, and unique identifying numbers for new beneficial owners, ensuring they meet §1010.380 verification rules.
• Audit trail retention. Store confirmation receipts, submission IDs, and supporting evidence for five years to respond to FinCEN inquiries or examinations.

Operational priorities

• Workflow automation. Integrate equity management, HR, and entity management systems with BOI alerting so legal teams can initiate updates within days.
• Subsidiary governance. Extend CTA controls to majority-owned subsidiaries that are not otherwise exempt, especially holding companies created for acquisitions.
• Attestation cadence. Institute quarterly certifications from business unit leaders confirming no reportable changes were missed.

Enablement moves

• Deploy dashboards tracking submission timeliness, outstanding updates, and document expirations to evidence program effectiveness.
• Conduct tabletop exercises simulating enforcement inquiries so counsel can respond within statutory timelines.

Sources

• FinCEN Beneficial Ownership Information Small Entity Compliance Guide
• FinCEN BOI Reporting Frequently Asked Questions

Zeph Tech automates CTA triggers, document vaulting, and update submissions to keep beneficial ownership programs enforcement-ready.

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