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Next Steps for Companies that Filed CTA Reports

Millions of reporting companies breathed a sigh of relief on March 21, 2025, when the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempted all domestic entities from...more

End of the Road: FinCEN Adopts Interim Final Rule Virtually Eliminating CTA Filing Requirements

On March 21, 2025, the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempts all domestic entities from beneficial ownership information reporting requirements under the...more

Whiplash: FinCEN Reverses Course, Delays CTA Enforcement Once Again

On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more

The Time Has Come: Court Reinstates CTA Filing Requirements, FinCEN Sets New Deadline For Compliance

AT A GLANCE - On February 17, 2025, the US District Court for the Eastern District of Texas stayed its January 7 order, enjoining enforcement of the Corporate Transparency Act and suspending the effectiveness of the...more

Not Quite Yet: Supreme Court Stays CTA Injunction, But Filing Requirements Remain Suspended

AT A GLANCE - The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more

On Again, Off Again: Fifth Circuit Again Suspends Corporate Transparency Act Filing Requirements

On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the...more

Fifth Circuit Reinstates Corporate Transparency Act Filing Requirements; FinCEN Provides Short Extension to Year-End Compliance...

On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion by the federal government to stay the nationwide preliminary injunction that had suspended enforcement of the Corporate...more

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