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Money transmitter licensing

What is a BOIR and do I still have to file one?

Reviewed July 2026

Short answer

A BOIR is the beneficial ownership information report the Corporate Transparency Act requires certain companies to file with FinCEN, identifying the individuals who own or control the company. Under FinCEN's March 2025 interim final rule, companies formed in the United States are exempt from filing; the requirement currently applies to foreign companies registered to do business in the US. Verify the current rule at fincen.gov/boi before filing or relying on the exemption, because the requirement has changed direction more than once.

The Corporate Transparency Act originally required most US-formed companies to report their beneficial owners, the individuals who own or control the company, to FinCEN through the free BOI E-Filing system. After court challenges and enforcement pauses, FinCEN's March 2025 interim final rule removed the filing requirement for domestic companies and US persons, leaving it in place for foreign reporting companies, meaning entities formed under foreign law that are registered to do business in a US state.

Two practical points for licensed businesses. First, the rulemaking is not finished, so check FinCEN's BOI page before paying anyone to file for a US-formed entity, and before relying on the exemption. The government filing itself is free when required; paid look-alike filing sites are a known trap. Second, a BOIR exemption changes nothing about state licensing disclosures: money transmitter and other license applications collect their own ownership and control-person information with background checks, and those never paused. Our guide to the full federal filing set for money services businesses is at /fincen-compliance-filings.

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