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How Did We Get Here? The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and was enacted as part of the Anti-Money Laundering Act of 2020....more
In a whirlwind series of announcements, the Treasury Department and FinCEN have suspended all Corporate Transparency Act (CTA) reporting and enforcement for domestic entities indefinitely. On Feb. 27, FinCEN announced that...more
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
On March 1, 2025, the U.S. Department of the Treasury announced that it will not enforce the Corporate Transparency Act (CTA) against U.S. citizens or domestic reporting companies or their beneficial owners. Treasury also...more
The U.S. Department of the Treasury announced on March 2, 2025 that it will not take any enforcement action against U.S. citizens and legal entities formed in the United States or their beneficial owners in connection with...more
On March 2, 2025, the U.S. Treasury Department announced it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies, or beneficial owners of domestic reporting companies under the Corporate...more
U.S. citizens and domestic companies will no longer be subject to the CTA or its reporting requirements. Just under two weeks after the Financial Crimes Enforcement Network (FinCEN), an enforcement bureau within the U.S....more
On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury announced that it will not be issuing any fines or penalties or taking any other enforcement actions against any...more
What Happened? On February 18, 2025, the last of the nationwide injunctions enjoining enforcement of the Corporate Transparency Act (“CTA”), Smith, et al. v. U.S. Department of the Treasury, et al., (E.D. Tex.), was stayed,...more
In a March 2, 2025 press release, the US Treasury Department announced that not only will it not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
On February 27, 2025, FinCEN issued a release providing 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...more
In a press release issued on March 2, 2025, the United States Department of the Treasury announced that “with respect to the Corporate Transparency Act…[it will] not enforce any penalties or fines against U.S. citizens or...more
On February 27, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a release announcing that it intends to issue an interim final rule by March 21, 2025 that will extend the current deadlines to file or...more
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
On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it would not issue any fines or penalties or take any other enforcement actions against any companies based on a failure to file or...more
On March 2, 2025, the U.S. Treasury Department issued a press release announcing that, for now, the Department will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under...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 February 18, 2025, a U.S. District Court for the Eastern District of Texas stayed the preliminary injunction which halted enforcement of the Corporate Transparency Act’s (CTA) reporting requirement....more
On February 17, 2025, a U.S. federal court granted the U.S. federal government’s motion to lift a nationwide injunction in place, that was preventing the enforcement by the Financial Crimes Enforcement Network (“FinCEN”) of...more
On January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) issued by a federal judge in Texas (Texas...more
What Happened? On February 18, 2025, the last of the nationwide injunctions enjoining enforcement of the Corporate Transparency Act (“CTA”), Smith, et al. v. U.S. Department of the Treasury, et al., (E.D. Tex.), was...more
Until just recently, the enforcement of the Corporate Transparency Act (CTA) was on hold under two separate nationwide injunctions (Texas Top Cop Shop, Inc. v. Bessent—formerly, Texas Top Cop Shop, Inc. v. McHenry and Texas...more
On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) previously issued in Smith v. US...more
The beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. The CTA generally requires “reporting companies” (any domestic or foreign entity registered...more
On February 18, 2025, the US District Court for the Eastern District of Texas in Smith v. US Department of the Treasury, No. 6:24-cv-336-JDK, entered an order staying (pausing) the nationwide preliminary injunction against...more