After the March 2025 interim final rule, only foreign reporting companies must file BOI reports. Here is exactly what makes an entity a foreign reporting company, who this affects, and what they must file.
By Alif Al Razi, Tax & Compliance Lead, Anonymousllc.co · Last updated 2026-05-21
Regulatory disclosure: This page reflects the March 21, 2025 FinCEN interim final rule (90 FR 13688). Foreign reporting company obligations remain active. Track any changes at /boi/status-tracker/.
A foreign reporting company is an entity formed under the law of a foreign country that is registered to do business in any US state or tribal jurisdiction by filing a document with a secretary of state or similar office. Two conditions must both be met:
A UK Limited company that files a Certificate of Registration as a Foreign Corporation with the Delaware Division of Corporations. This entity is a foreign reporting company. It must file a BOI report with FinCEN.
A Canadian corporation that files a Certificate of Authority (Foreign Entity Registration) with the Wyoming Secretary of State. This is a foreign reporting company. BOI filing required.
A Wyoming LLC formed by a UK citizen through Anonymousllc.co. The entity was formed under Wyoming law - it is a domestic reporting company regardless of who owns it. Currently exempt from BOI filing under the March 2025 rule.
A German GmbH that opens a US bank account but does not register with any US secretary of state. This entity is not a foreign reporting company because it has not filed a registration document in any US state. No BOI obligation.
Foreign reporting companies must submit a Beneficial Ownership Information Report (BOIR) to FinCEN through the BOI E-Filing system at boiefiling.fincen.gov. The report includes:
Foreign reporting companies face the full enforcement framework under 31 USC 5336(h): civil penalties up to $500 per day for willful violations and criminal penalties up to $10,000 and/or 2 years imprisonment. See the full breakdown at /boi/penalties/.
Anonymousllc.co handles the full BOI filing for foreign reporting companies - $150 flat, including beneficial owner data collection, ID document upload, and FinCEN ID setup.