Enforcement of the Corporate Transparency Act (CTA) will no longer require the filing of beneficial ownership information (BOI) for U.S. small businesses. In a press release on March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) and Treasury Department announced that U.S. companies and U.S. persons are not required to file beneficial ownership information reports (BOIRs) under the CTA, effective immediately.
In an interim final rule, set to be published in the Federal Register, FinCEN revises the regulatory definition of “reporting company” to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction. The FinCEN notice states, “Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN.”
The CTA, enacted by Congress in 2020, mandates that companies earning $5 million or less in revenue and employing twenty or fewer individuals must file beneficial ownership reports which included contact information of owners along with copies of their IDs with the Financial Crimes Enforcement Network (FinCEN) of the Department of the Treasury.
CBP Updates Section 232 FAQs
U.S. Customs and Border Protection (CBP) has updated the Frequently Asked Questions (FAQ) page on Section 232 tariffs for aluminum and steel providing new guidance on the recently imposed 25 percent tariffs on steel and aluminum products and derivatives which became effective on March 12, 2025. These new FAQs provide some clarification on how to determine the value of aluminum or steel content of derivative products and reporting instructions for the countries of smelt and casting for aluminum and melt and pouring for steel when the country is not known.
Under the Section 232 tariff action, the tariff on covered aluminum and steel derivatives outside of HTS chapters 73 and 76 only applies to the steel or aluminum content of the derivative article. In the updated FAQs, CBP clarifies that the value of aluminum or steel content for derivative products outside of chapters 73 and 76 “is the total price paid or payable for that content, which is the total payment (direct or indirect, and exclusive of any costs, charges, or expenses incurred for transportation, insurance, and related services incident to the international shipment of the merchandise from the country of exportation to the country of importation) made/to be made for the steel/aluminum content by the buyer to, or for the benefit of, the seller of the steel/aluminum content.”
The Section 232 tariffs on derivative articles do not apply to products processed in another country from steel articles melted and poured, or aluminum articles smelted and cast in the U.S. For steel derivatives, if the importer does not know the country of melt and pour, the CBP FAQs state that filers can report OTH. For aluminum derivatives, the FAQs indicate that the filer “as an interim solution, may report “RU” for Russia if the filer does not know the country of smelt or cast; and pay the 200 percent Russia aluminum duty.” The FAQs continue, “Importers may submit a post-summary correction to update the country of smelt or cast when they obtain information on the actual countr(ies) of smelt or cast. For a long-term solution, CBP is looking into other options for reporting an unknown country of smelt or cast, which will also require paying the 200 percent Russia aluminum duty.” Furthermore, the FAQs clarify that CBP does not require an aluminum certificate of analysis to be submitted at the time of entry. However, the agency retains the authority to request the importer provide an aluminum certificate of analysis if it is necessary to verify compliance with the relevant entry requirements for the imported item.
EPA Begins Deregulation Efforts
The U.S. Environmental Protection Agency (EPA), on March 12, 2025, announced in what Administrator Lee Zeldin called “the greatest and most consequential day of deregulation in U.S. history” the intention to review or roll back over 30 environmental regulations. This major deregulatory initiative is aimed at reducing compliance costs, “unleashing” energy and industry, and giving more authority to states.
Key regulations highlighted in the announcement by the EPA include:
- Reconsidering the Biden-era rule limiting CO2 emissions from power plants
- Reconsidering the National Ambient Quality Standards (NAAQS) for fine particulate matter or soot (PM₂.₅)
- Reconsidering emissions standards for cars/trucks
- Overhauling of the social cost of carbon (SCC) metric used in EPA decision-making
- Ending the Biden-era Good Neighbor Plan for ozone, which expanded federal limits on smog-forming emissions drifting across state lines
- Reconsidering the mandatory greenhouse gas (GHG) Reporting Program
- Revising the definition of “Waters of the U.S.” (WOTUS) following the Supreme Court’s Sackett decision which narrowed the interpretation of navigable waters under the Clean Water Act (CWA).
Significantly, the EPA will also reconsider the 2009 Greenhouse Gas Endangerment Finding, which found greenhouse gases (GHG) endanger both public health and the environment, as well as regulations that rely on the scientific finding. Under the Clean Air Act (CAA), the EPA is required to regulate air pollutants if it finds that they “cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare.” The endangerment finding gives the EPA the legal authority to regulate GHGs and has served as the basis for many GHG regulations.
Federal Contractor Minimum Wage Decreased
President Trump has issued an executive order (EO) effectively lowering the minimum wage for federal contractors. In EO “Additional Rescissions of Harmful Executive Orders and Actions,” Trump revoked a Biden-era EO which raised the minimum wage for federal contractors to $15 per hour beginning on January 30, 2022, with further annual increases. The federal contractor minimum wage as of January 1, 2025, was $17.75 per hour.
The minimum wage generally applies to workers performing work on or in connection with
- Procurement contracts for construction covered by the Davis-Bacon Act (DBA);
- Service contracts covered by the Service Contract Act (SCA);
- Concessions contracts, including any concessions contract excluded from the SCA by the Department of Labor’s regulations at 29 CFR 4.133(b); and
- Contracts in connection with federal property or lands and related to offering services for federal employees, their dependents, or the general public.
With the rescission of President Biden’s 2021 EO 14026, the minimum wage for federal contractors reverts to $13.30 per hour, established by a 2014 EO issued by President Obama.
EU Delays Retaliatory Tariffs; Moves to Join Canadian WTO Challenge
The European Union (EU) is postponing the tariffs levied on the U.S. previously set to take effect on April 1. On March 20, 2025, EU Trade Commissioner Maroš Šefčovič announced that the EU would wait to impose tariffs on €26 billion of U.S. exports in retaliation for the 25 percent tariffs on all steel and aluminum imports imposed by the U.S. under Section 232 as of March 12, 2025.
Originally, the EU had planned on taking a two-step response, lifting the suspension of tariffs on the €26 billion of U.S. exports, which were originally imposed in 2018 and 2020 in response to the 2018 Section 232 tariff action, as well as developing a new list of retaliatory measures to impose in mid-April. The first step has been delayed and will be combined with the second step.
The EU will also take into consideration any reciprocal tariffs imposed by the Trump administration on April 2. “In the light of the recent announcement that the United States are planning to introduce additional tariffs on the second of April, we are now considering aligning the timing of the two sets of EU countermeasures so we can consult with the member states on both lists simultaneously,” Šefčovič said. “And this would give us extra time for negotiations with our American partners to try to find a mutually agreeable solution, which clearly would be the preference for us.” The EU is also moving to join Canada’s World Trade Organization (WTO) case challenging the Section 232 steel and aluminum tariffs. On March 13, 2025, Canada submitted a formal request for consultation to the WTO’s Dispute Settlement Body, the first step in a WTO dispute. On March 20, the EU formally requested to join the consultation, stating that the EU “has a substantial trade interest” in the consultations as the tariffs “at issue also concern imports from the EU”, impacting a total of €26 billion of EU exports or approximately 5 percent of total EU goods exported to the U.S.