Literally hours after our last email update on December 27th, we learned a different panel of the Fifth Circuit Court of Appeals issued an order vacating the previous panel’s December 23rd stay of the injunction. As a result, the injunction issued on December 3rd is back in effect and reporting companies are once again not required to file the beneficial ownership information report with FinCEN and are not subject to any liability if they do not file while the injunction is in place.
Reporting companies are still able to voluntarily submit their report electronically through a secure filing system via the Financial Crime Enforcement Network (FinCEN) website. To file, and for more information/resources, follow this link: https://fincen.gov/boi.
Due to ambiguity as it relates to providing professional services for this BOI filing and it being interpreted by some as a potential unauthorized practice of law, including but not limited to state lawmakers and insurance carriers, AHP cannot assist clients with this filing nor advise clients on this topic. We are, however, providing this as a public service announcement and directing those affected to the FinCEN website link above in order to meet any potential filing requirements by the applicable due date. We also encourage you to consider contacting legal counsel for assistance.
