News & Analysis as of

Disclosure Requirements Compliance FinCEN

McCarter & English, LLP

The Evolution of the CTA: FinCEN Removes Beneficial Ownership Reporting Requirements for US Companies and US Persons, Sets New...

On March 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is issuing an interim final rule to remove the Corporate Transparency Act’s (CTA) beneficial ownership...more

Cole Schotz

CTA is No Longer Applicable to U.S. Entities and U.S. Persons; Foreign Entities Face New Rules

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On Friday, March 21, 2025, FinCEN announced an interim rule that removed Beneficial Ownership (“BOI”) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act (the “CTA”). FinCEN’s new...more

Wyrick Robbins Yates & Ponton LLP

FinCEN Issues Revised Corporate Transparency Act Rule; Domestic Companies Exempt

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule under the Corporate Transparency Act. The revised rule changes the definition of “reporting company” to mean any entity that...more

Perkins Coie

Corporate Transparency Act: Treasury Announces No Enforcement for Reporting Failures by U.S. Citizens and Domestic Reporting...

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Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

Ruder Ware on

The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic...more

Cole Schotz

CTA is Effectively on Pause (Again)

Cole Schotz on

On Thursday, February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any enforcement actions against companies based on the failure to file or update beneficial ownership information (“BOI”)...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Hinshaw & Culbertson LLP

UPDATE: FinCEN Pauses Penalties for CTA Reporting Noncompliance and Signals Additional Changes

As discussed in our previous alert, in connection with the recent reinstatement of the Corporate Transparency Act (CTA) and its reporting obligations, FinCEN issued an announcement (the "Prior Announcement") extending the...more

Verrill

NEED MORE COWBELL: FinCEN Not Satisfied with Current Deadlines and Requirements under the Corporate Transparency Act

Verrill on

On February 27, 2025, FinCEN issued a press release announcing future changes but giving no guidance about the scope of those changes: “No later than March 21, 2025, FinCEN intends to issue an interim final rule that...more

McNees Wallace & Nurick LLC

FinCEN Suspends CTA Enforcement

On February 18, 2025, the United States District Court for the Eastern District of Texas reinstated reporting obligations under the Corporate Transparency Act (CTA) (31 U.S.C. §5336), requiring reporting companies to resume...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Will Not Enforce the CTA Until Interim Rule is Effective

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or initiate any other enforcement action against companies that do not file or update...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act is Again on Hold

On February 27, 2025, FinCEN announced “that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI)...more

Rosenberg Martin Greenberg LLP

CTA Whiplash Continues – FinCEN Announces Compliance is Mandatory but Extends Deadline – RMG

Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (the “CTA”) is once again mandatory. On February 18, 2025, the CTA was reinstated by the U.S. District Court for the Eastern District of...more

Cadwalader, Wickersham & Taft LLP

The Corporate Transparency Act’s Reporting Obligations Are Back in Force

The Corporate Transparency Act’s (CTA) reporting obligations are back in effect after a nationwide court order blocking the CTA’s implementing regulations was stayed on February 17, 2025.  Most reporting companies are now...more

Tonkon Torp LLP

Corporate Transparency Act – BOI Report Filings Mandatory Again

Tonkon Torp LLP on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued an Order in the Smith case lifting the preliminary injunction against enforcement of the CTA. Therefore, BOI Report filings are once again...more

Greenberg Glusker LLP

Corporate Transparency Act Back in Effect: Updated BOI Compliance Deadlines

Greenberg Glusker LLP on

UPDATE as of 2/20/25: The on-again, off-again Corporate Transparency Act (the “CTA”) mandatory beneficial ownership reporting is now back in effect. On February 18, 2025, the Texas federal district court in Smith v. United...more

Lowenstein Sandler LLP

Back to the Future: Compliance with the CTA is Compulsory Once Again

Lowenstein Sandler LLP on

Regular readers of our prior client alerts know that compliance with the Corporate Transparency Act’s (CTA) beneficial ownership requirements has been on-again-off-again multiple times over the last few months following...more

Saul Ewing LLP

FinCEN Reinstates Beneficial Ownership Reporting Deadline Following Court Ruling

Saul Ewing LLP on

The Corporate Transparency Act (CTA), enacted in 2021, mandates that companies disclose their true ownership to the Financial Crimes Enforcement Network (FinCEN) to combat illicit financial activities. However, its...more

Hinckley Allen

CTA Reinstated Again With New Reporting Deadlines

Hinckley Allen on

On February 18, 2025, Judge Jeremy D. Kernodle of the Eastern District of Texas stayed his own preliminary injunction, which had blocked the enforcement of the Corporate Transparency Act (“CTA”), pending the government’s...more

Nelson Mullins Riley & Scarborough LLP

Corporate Transparency Act Reporting Obligations Reinstated; Deadline Extended 30 Days

On February 19, 2025, FinCEN released a statement that BOI reporting obligations under the CTA are back in effect, after a recent U.S. District Court decision in the ongoing case of Smith et al. v. U.S. Department of the...more

McGlinchey Stafford

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

McGlinchey Stafford on

As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect

Fox Rothschild LLP on

The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Allen Barron, Inc.

BOI Reporting Requirements are Back in Force as of 2/18/2025

Allen Barron, Inc. on

Attention: FinCEN BOI reporting requirement deadline is now set for March 21, 2025. A decision yesterday, February 18, 2025, in the case of Smith, et al. v. U.S. Department of Treasury, et al., 6:24-cv-00336, has returned...more

Kerr Russell

The Corporate Transparency’s Act’s Impact on Medical Practices: Understanding Physicians’ Obligations Amid Recent Judicial and...

Kerr Russell on

Medical practices across the United States are grappling with new compliance obligations under the Corporate Transparency Act (CTA). This article addresses the CTA’s applicability to medical practices, its current legal...more

Tonkon Torp LLP

Oregon HOAs Should Continue to Prepare for Compliance with Corporate Transparency Act

Tonkon Torp LLP on

The Corporate Transparency Act (CTA), enacted to combat financial crimes, requires certain entities to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). While legal challenges...more

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