Update: FinCEN BOIR filing requirements

**TO ALL CMR CLIENTS** Please note that the December 3, 2024, injunction prohibiting the Financial Crimes Enforcement Network (FinCEN) from enforcing the BOIR filing requirements has been reversed on appeal. Thus, the FinCEN BOIR filing requirements have become MANDATORY again. Extensions have been issued for filing deadlines as follows:

• If the reporting company existed BEFORE January 1, 2024, the deadline for filing is now January 13, 2025.
• If the reporting company was created between September 4, 2024, and December 3, 2024, the deadline for filing is January 13, 2025.
• If the reporting company was created between December 3, 2024, and December 23, 2024, there is an additional 21 days from the company’s original filing deadline to make the filing.

Reporting companies that are formed on or after January 1, 2025, have 30 days to make their initial filing.

Please contact Melanie Roosa or Julianna Engel in our office at 845-565-1100 for any questions.