Certain non-U.S. limited liability corporations (LLCs) that were formed under the law of a foreign country and authorized to do business in New York State must prepare now to ensure compliance with new beneficial ownership information (BOI) disclosure requirements, or potentially face hefty penalties.
The New York LLC Transparency Act (NY LLCTA), which took effect Jan. 1, is far narrower in scope than originally proposed. This is because New York Governor Kathy Hochul, on Dec. 19, 2025, vetoed amendments that would have expanded the BOI disclosure requirements to non-U.S. and U.S.-based LLCs.
