Update: Courts Again Block Enforcement of Corporate Transparency Act

Latest Update: On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced it will not be enforcing the current Corporate Transparency Act (“CTA”) deadline of March 21, 2025. On March 2, 2025, the Department of the Treasury declared that it will not enforce CTA penalties or fines against U.S. citizens or domestic companies and their beneficial owners, even after the new deadlines are set. New deadlines and rules will be forthcoming. Please see our update for more information.

On January 23, 2025, and February 18, 2025, the preliminary injunctions blocking enforcement of the Corporate Transparency Act (“CTA”) nationwide were stayed. CTA filings are now required with deadlines extended to at least March 21, 2025. Please see our update for more information.

On January 23, 2025, this injunction was stayed by the Supreme Court of the United States. However, a similar order from Smith v. Department of the Treasury was in effect, so CTA filings were not required until the January 23, 2025, and February 18, 2025, orders.

On December 26, 2024, in its second order of the week related to Texas Top Cop Shop, Inc. et al. v. Garland et al., No. 4:24-CV-478 (E.D. Texas 12/3/24), the Fifth Circuit Court of Appeals restored the District Court’s preliminary injunction blocking enforcement of the Corporate Transparency Act (“CTA”) against all companies.  Earlier, on December 23, 2024, a separate panel of judges on the Fifth Circuit had stayed the injunction pending appeal, and the Financial Crimes Enforcement Network had provided extended deadlines as detailed here. The December 26 order vacated the stay of the injunction, again blocking any enforcement of the CTA.

Companies may still voluntarily file Beneficial Ownership Information Reports (“BOI Reports”) or may prepare to file them at a later time if the CTA’s requirements are rendered enforceable, but CTA compliance is not required at this time. Please see our prior article covering the CTA for guidance on preparing and filing BOI Reports.

If you have any questions or need assistance with your company’s CTA requirements, please reach out to a Hinckley Allen attorney.