Compliance Briefing — September 2, 2025
Entities formed in 2025 now have only 30 days to lodge Beneficial Ownership Information reports with FinCEN, putting September incorporations on a compressed documentation clock under the Corporate Transparency Act.
Executive briefing: Beginning January 1, 2025, corporations, LLCs, and similar entities created or registered in the United States must file Beneficial Ownership Information (BOI) with the Financial Crimes Enforcement Network (FinCEN) within 30 calendar days of receiving notice that their formation is effective. September formations therefore face immediate documentation tasks to assemble ownership attestations, verify identification documents, and deliver filings through the BOI e-filing system before the statutory clock expires. FinCEN may impose civil penalties of $500 per day for willful failures to report and refer egregious cases for criminal enforcement.
Key compliance checkpoints
- Entity intake triage. Confirm at onboarding whether a new entity qualifies for one of the 23 reporting exemptions under 31 CFR 1010.380(c)(2); if not, trigger BOI data collection immediately.
- Identity verification. Capture acceptable ID images for beneficial owners and company applicants, ensuring expiration dates extend beyond the submission window to avoid rejection.
- Ongoing change monitoring. Establish calendar controls so any changes in ownership or control reported in September are re-filed within 30 days, as the rule applies the same deadline to updates.
Operational priorities
- Automation hooks. Integrate formation workflows with the BOI e-filing API so compliance teams can pre-populate entity, owner, and applicant data directly from governance systems.
- Training. Brief legal, finance, and corporate-secretary teams on FinCEN’s guidance covering acceptable documentation, beneficial owner definitions, and consequences for willful misstatements.
- Evidence retention. Store submission receipts, ownership attestations, and due diligence notes for at least five years to respond to examinations.
Enablement moves
- Map exemption eligibility for common structures—such as venture portfolio companies that may lose the “large operating company” exemption—before filings are due.
- Embed privacy controls so BOI data is encrypted at rest and only accessible to personnel authorized under FinCEN’s access rules.
Sources
- FinCEN final rule on Beneficial Ownership Information reporting (87 FR 59498)
- FinCEN BOI filing instructions and small entity compliance guide
Zeph Tech automates BOI eligibility checks, collects identity evidence, and pushes filings to FinCEN within the 30-day clock.