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Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
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Days after the United States Treasury Department and its Financial Crimes Enforcement Network (FinCEN) announced it was suspending enforcement the Corporate Transparency Act (CTA), (you can read about that in our last client...more
On March 2, the United States Treasury Department announced a permanent suspension of Corporate Transparency Act (“CTA”) enforcement against domestic reporting companies and their beneficial owners. Foreign companies and...more
UPDATE 2/26/25: There continue to be developments regarding the Corporate Transparency Act ("CTA") and the applicability of related filing obligations. Please note the following recent updates...more
On Tuesday, February 18, 2025, a Federal district judge in Texas lifted the nationwide preliminary injunction issued in Smith v. U.S. Dept. of Treasury, which means that the Corporate Transparency Act (“CTA”) and its...more
As of the posting of this article, reporting companies nationwide once again need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines. FinCEN has set the...more
On February 18, a federal court lifted the remaining injunction blocking enforcement of the Corporate Transparency Act (“CTA”), previously discussed. In response, FinCEN has stated that the reporting deadline for existing...more
CTA filings are obligatory again. Most reporting companies have until March 21, 2025 to complete their filings. If you adopted a wait-and-see posture in regard to making your CTA BOIR filings, the wait is unfortunately over....more
Effective February 18, 2025, and until further notice, beneficial ownership information report filings under the Corporate Transparency Act are once again legally required. The deadline for most reporting companies to file...more
On Feb. 17, 2025, the U.S. District Court for the Eastern District of Texas (in Smith, et al. v. U.S. Department of the Treasury, et al.) granted the federal government’s motion to stay a nationwide preliminary injunction...more
On February 18, 2025, the U.S. District Court for the Eastern District of Texas (EDTX) lifted the nationwide injunction to the Financial Crimes Enforcement Network's (FinCEN) enforcement of the Beneficial Ownership...more
Companies are once again required to comply with the CTA and its reporting obligations. As discussed in our previous update, last month the Supreme Court of the United States (SCOTUS) stayed (i.e., suspended the effect of)...more
On February 17, a federal judge in Texas lifted a preliminary injunction issued in Smith v. United States Department of the Treasury, removing the last legal hurdle to the enforcement of the Corporate Transparency Act...more
The Corporate Transparency Act (CTA) remains on hold due to a nationwide injunction granted by a federal District Court in Texas in Smith v. U.S. Department of the Treasury. However, given pending legal battles and...more
The Corporate Transparency Act (“CTA”) continues to take reporting companies on a roller coaster ride. Now, there are not just one, but two Eastern District of Texas federal cases challenging the requirement for certain...more
Enforcement of the Corporate Transparency Act (the “CTA”) remains on hold while litigation proceeds, and reporting companies are therefore not required to file reports at this time. However, reporting companies may continue...more
On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more
(2/6/25) Update as of February 5, 2025: The government appealed the nationwide injunction blocking CTA enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN updated its...more
On February 5, 2025, the United States filed a motion in the case of Samantha Smith, et al., v. United States Department of Treasury, et al., to stay the order of the Federal District Court for the Eastern District of Texas,...more
On January 23, the U.S. Supreme Court lifted the nationwide injunction entered by the federal district court in the Eastern District of Texas in the case styled Texas Top Cop Shop v. McHenry, which had barred enforcement of...more
On January 23, 2025, the Supreme Court of the United States granted the federal government’s motion to stay the nationwide injunction preventing enforcement of the Corporate Transparency Act (the “CTA”) entered by the United...more
The Supreme Court has weighed in on the ongoing battle concerning the Corporate Transparency Act (the CTA). As we previously wrote, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a...more
Last Friday, the United States Supreme Court lifted a nationwide injunction originally issued by the U.S. District Court for the Eastern District of Texas (and later upheld by the Fifth Circuit Court of Appeals) in Texas Top...more
On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more
FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more
A flurry of activity in the courts and guidance from FinCEN this week has the Corporate Transparency Act back in the news. However, the recent activity does not result in any immediate change for businesses. Filing beneficial...more