News & Analysis as of

Preliminary Injunctions Anti-Money Laundering Constitutional Challenges

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

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act - UPDATED February 21,2025

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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

Shipman & Goodwin LLP

Whiplash Redux - The Corporate Transparency Act is Back

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The preliminary injunction in Smith, et al. v. U.S. Department of the Treasury that was still pausing any required filings by reporting companies under the Corporate Transparency Act (CTA) was lifted on February 17, 2025 by...more

Holland & Knight LLP

Corporate Transparency Act: Government Appeals Smith Case, Seeks Reporting Rule Reinstatement

Holland & Knight LLP on

Here are the latest developments in the ongoing Corporate Transparency Act (CTA) saga...more

Womble Bond Dickinson

Corporate Transparency Act Compliance Still on Hold, For Now

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On January 23, the U.S. Supreme Court lifted a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the CTA), a law requiring millions of business entities to report information about their...more

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

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On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more

Flaster Greenberg PC

Corporate Transparency Act Updates

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(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

Saul Ewing LLP

Corporate Transparency Act Reporting Requirements Still on Hold

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

Pillsbury Winthrop Shaw Pittman LLP

Beneficial Ownership Reporting: Litigation, Pending Legislation and Possible Future Executive Action Have Left the Fate of the...

The saga of the CTA continues. Adopted in January 2021, the Corporate Transparency Act (CTA) is intended to assist in identifying beneficial ownership and control of entities operating in the United States in order to...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

Verrill on

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

Adams & Reese

SCOTUS Allows Enforcement of Corporate Transparency Act; FinCEN Says Reporting is Voluntary for Now

Adams & Reese on

As the calendar turns to 2025, there is a new development in the off-again, on-again Corporate Transparency Act (“CTA”). This time, the highest court has weighed in....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

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

Ballard Spahr LLP on

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

Dickinson Wright on

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...

Hinshaw & Culbertson LLP on

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

DLA Piper on

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

Seyfarth Shaw LLP

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

Seyfarth Shaw LLP on

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

Dickinson Wright on

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...

Hinshaw & Culbertson LLP on

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

Fox Rothschild LLP

Federal Appeals Court Stays Nationwide Injunction of Corporate Transparency - Act #2

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An appellate panel has stayed the nationwide injunction issued by a federal judge in Texas that halted enforcement of the Corporate Transparency Act (CTA). Hours later, the U.S. Financial Crimes Enforcement Network (FinCEN)...more

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