The Corporate Transparency Act carries real penalties for willful non-compliance — up to $500 per day in civil fines and up to $10,000 and two years imprisonment for criminal violations. Here is the full penalty framework and who faces enforcement today.
By Alif Al Razi, Tax & Compliance Lead, Anonymousllc.co · Last updated 2026-05-21
Regulatory disclosure: Under the March 2025 interim final rule, domestic reporting companies are exempt from BOI filing. Penalties apply only to obligated entities (currently foreign reporting companies). Track status at /boi/status-tracker/.
Under 31 USC 5336(h)(1)(A), any person who willfully provides or attempts to provide false or fraudulent beneficial ownership information to FinCEN, or willfully fails to report complete or updated information, may be subject to a civil penalty of up to $500 for each day that the violation continues.
This is not a one-time fine. The penalty accrues daily from the date the violation began. For a filing that is 60 days late, the theoretical maximum civil penalty is $30,000. For 365 days, $182,500. FinCEN has discretion in enforcement — not every late filing will be penalized at the maximum rate — but the statutory authority exists.
The civil penalty amount is subject to annual inflation adjustment under the Federal Civil Penalties Inflation Adjustment Act. The $500/day figure is the base amount from the statute; the adjusted amount may be slightly higher in any given year.
Under 31 USC 5336(h)(1)(A), a person who willfully violates BOI reporting requirements may also face criminal penalties:
Criminal penalties are reserved for willful and knowing violations. A person who files a BOI report containing information they know to be false, or who deliberately refuses to file despite being aware of the requirement, is the target. A person who makes a good-faith mistake or is unaware of the requirement is unlikely to face criminal prosecution, though civil penalties could still apply.
Both civil and criminal penalties require willfulness. In the context of BSA/AML enforcement, “willful” generally means the person acted with knowledge that their conduct was unlawful, or acted with reckless disregard of a known legal duty. It does not require specific intent to violate the law — knowing about the requirement and choosing not to comply is sufficient.
Key factors FinCEN and DOJ may consider: whether the person received notice of the filing obligation, whether they had access to the information needed to file, whether they made any attempt to comply, and whether there is evidence of deliberate concealment.
The CTA includes a safe harbor provision under 31 USC 5336(h)(3)(C). A person who submits inaccurate information in a BOI report is not subject to civil or criminal penalties if:
This safe harbor covers honest mistakes — a misspelled name, an old address, a transposed digit. It does not cover deliberately false information or complete failure to file.
The March 2025 interim final rule narrowed enforcement significantly. Domestic reporting companies and their beneficial owners are exempt from filing. FinCEN cannot penalize someone for failing to file a report they are not required to submit. This means:
If FinCEN reinstates domestic filing obligations in a future rule, the penalty framework would apply to domestic companies from the effective date of the new rule forward — not retroactively to the current exemption period.
If you are a foreign reporting company that has missed a filing deadline:
Anonymousllc.co files BOI reports for foreign reporting companies at $150 flat. Accurate, complete, on time. No penalty risk.
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