News & Analysis as of

Financial Crimes Preliminary Injunctions

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Spilman Thomas & Battle, PLLC

Court Lifts Injunction on Corporate Transparency Act – Most Companies Must File by March 21, 2025

After months of litigation, the Corporate Transparency Act (“CTA”) is once again effective, and most companies subject to the CTA are required to file Beneficial Ownership Information (“BOI”) reports with the U.S. Treasury’s...more

DLA Piper

CTA Update: Supreme Court Grants Stay of Preliminary Injunction on Corporate Transparency Act

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On January 23, 2025, the Supreme Court of the United States granted the federal government a stay of the preliminary injunction foreclosing enforcement of the Corporate Transparency Act (CTA) in McHenry v. Texas Top Cop Shop,...more

McDermott Will & Emery

Corporate Transparency Act Update: Nationwide Injunction Continues

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On January 23, 2025, the Supreme Court of the United States issued a stay of the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) and the Beneficial Ownership...more

Tucker Arensberg, P.C.

Update: Despite U.S. Supreme Court Decision, Enforcement of the Corporate Transparency Act (“CTA”) is Still On Hold

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On January 23, 2025, the U.S. Supreme Court lifted an injunction that had blocked enforcement of the CTA and its regulations, as originally issued by the U.S. District Court for the Eastern District of Texas on December 3,...more

Kohrman Jackson & Krantz LLP

CTA Reporting Remains Voluntary Despite Recent Supreme Court Decision

On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction issued in Texas Top Cop Shop, Inc. et al. v. Garland et al., creating further legal uncertainty surrounding the Corporate Transparency Act...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Fifth Circuit Issues an Expedited Appeal of CTA Nationwide Injunction

December was an eventful month for the Corporate Transparency Act (CTA). The latest court ruling in the CTA conflict occurred on December 26, 2024, in Texas Top Cop Shop, Inc., et al. v. Garland, et al., when the Fifth...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Allen Matkins

Seriously, The CTA Imposes Only "Minimal Burdens"?

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American businesses have been experiencing whiplash over the status of the Corporate Transparency Act.  In early December of last year, Judge Amos L. Mazzant's  preliminarily enjoined the CTA and its implementing...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

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Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

Ballard Spahr LLP

CTA Reporting Requirements Blocked Again

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It’s hard to keep track of the status of reporting obligations under the Corporate Transparency Act (CTA) these days, but in a second ruling during the holiday week, a court blocked the filing requirement again. ...more

Dickinson Wright

Fifth Circuit Reinstates CTA Injunction, FinCEN Still Accepting Voluntary Filings

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In a surprising reversal, on December 26, 2024, a panel of the Fifth Circuit Court of Appeals issued an Order that vacated (effectively reversing) the same court’s order from December 23, 2024, and reinstated a lower court’s...more

Vorys, Sater, Seymour and Pease LLP

CTA UPDATE – Fifth Circuit Reinstates Nationwide Preliminary Injunction

On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Inc., et al. v. Garland,...more

Hinshaw & Culbertson LLP

Yet Another Twist: Fifth Circuit Reinstates Nationwide Freeze on Enforcement of Corporate Transparency Act Filing Deadlines – What...

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Seventy-two hours after a motions panel of the U.S. Court of Appeals for the Fifth Circuit stayed the effect of a nationwide preliminary injunction imposed by a Texas federal district court blocking the reporting deadline for...more

DLA Piper

Fifth Circuit Vacates Stay of Corporate Transparency Act Injunction, Again Putting Deadlines on Hold

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On December 26, 2024, the US Court of Appeals for the Fifth Circuit vacated the stay entered by a motions panel days earlier, which would have allowed the government to enforce the Corporate Transparency Act (CTA) while it...more

Seyfarth Shaw LLP

The Saga Continues: Fifth Circuit Court Reinstates Nationwide Injunction on CTA Pausing FinCEN’s Recently Announced Reporting...

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The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury reset Corporate Transparency Act (CTA) reporting deadlines. However, on December 26, 2024, the Fifth Circuit Court of Appeals issued a...more

Pullman & Comley, LLC

Nationwide Injunction Halting Enforcement of CTA Reinstated

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The Fifth Circuit Court of Appeals has reinstated the stay with respect to Corporate Transparency Act (CTA) compliance which means that the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) is...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Corporate Transparency Act - Nationwide Injunction Reinstated

On December 26, 2024, the full U.S. Court of Appeals for the Fifth Circuit reinstated the stay on the government’s ability to enforce the Corporate Transparency Act (CTA), meaning that reporting companies are, for now, no...more

Seyfarth Shaw LLP

Fifth Circuit Court Stays Nationwide Injunction on CTA Enforcement - BOI Reporting Requirements Resume

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On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an order temporarily staying the nationwide preliminary injunction previously granted in Texas Top Cop Shop, Inc., et al. v. Garland, et al. While...more

Dickinson Wright

Fifth Circuit Reverses CTA Injunction, Deadline Extended

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On December 23, 2024, the Fifth Circuit Court of Appeals issued an Order which granted a stay of a lower court’s nationwide injunction against enforcement of the Corporate Transparency Act (CTA or the Act). Texas Top Cop...more

Hinshaw & Culbertson LLP

Fifth Circuit Overturns Preliminary Nationwide Injunction Against Corporate Transparency Act – FinCEN Announces Extension of...

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On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit lifted the preliminary injunction recently imposed by a Texas district court that had blocked the reporting deadline for filing Beneficial...more

Pullman & Comley, LLC

Corporate Transparency Act Enforcement Resumes with Extended Deadlines: January 1, 2025 Deadline Extended to January 13, 2025

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On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the previously issued nationwide injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., which had the effect of reinstating...more

Weintraub Tobin

Court Blocks Nationwide Injunction of the Corporate Transparency Act: Fifth Circuit Grants Stay Pending Appeal; Compliance Period...

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On December 23, 2024, the Fifth Circuit Court of Appeals granted the government’s emergency motion for a stay, effectively blocking a nationwide injunction issued by a district court against the Corporate Transparency Act...more

DLA Piper

Fifth Circuit Stays Injunction Halting Corporate Transparency Act’s Enforcement; Treasury Updates Deadline to January 13, 2025 for...

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On December 23, 2024, the US Court of Appeals for the Fifth Circuit issued an order granting the government's emergency motion for a stay pending appeal of the preliminary injunction against the Corporate Transparency Act...more

Ballard Spahr LLP

FinCEN Extends Deadlines in Light of Reinstatement of the CTA

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As noted in our client alert yesterday, the U.S. Court of Appeals for the Fifth Circuit reinstated the enforceability of the Corporate Transparency Act (CTA) and lifted the preliminary injunction issued by the U.S. District...more

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