News & Analysis as of

Preliminary Injunctions Constitutional Challenges U.S. Treasury

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Ballard Spahr LLP

CTA Litigation Updates: Federal Judge in Maine Rules CTA is Justified, While Texas Judge Allows CTA Enforcement; FinCEN Announces...

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Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more

McCarter & English, LLP

The Evolution of the CTA: Beneficial Ownership Information Reports Are Due by March 21, 2025

As of February 18, 2025, the US Department of the Treasury Financial Crimes Enforcement Network’s (FinCEN) Corporate Transparency Act (CTA) reporting requirements have been restored—at least temporarily. The new filing...more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Shipman & Goodwin LLP on

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

Orrick, Herrington & Sutcliffe LLP

DOJ contests court order blocking DOGE’s access to Treasury’s payment systems and records

On February 9, DOJ filed an emergency motion seeking to dissolve, modify or clarify a temporary restraining order issued by the U.S. SDNY, which prohibited certain political appointees and DOGE members from accessing the...more

Womble Bond Dickinson

Corporate Transparency Act Compliance Still on Hold, For Now

Womble Bond Dickinson on

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

Pierce Atwood LLP on

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

Flaster Greenberg PC on

(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

McGlinchey Stafford

FinCEN Commits to Extend CTA Reporting for 30 Days If Court Grants Stay of Injunction

McGlinchey Stafford on

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

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

Clark Hill PLC

CTA Litigation Update: Reporting Remains Voluntary

Clark Hill PLC on

On Jan. 23, the U.S. Supreme Court stayed the Dec. 5 nationwide injunction in Texas Top Cop Shop, Inc. v. Garland (E.D. Tex.) that had halted Corporate Transparency Act (“CTA”) enforcement nationwide. The stay of this...more

Bricker Graydon LLP

The CTA is Back in Play, with a Slight Extension - Update

Bricker Graydon LLP on

On January 23, 2025, the U.S. Supreme Court lifted the nationwide injunction that had previously blocked the enforcement of the Corporate Transparency Act (CTA) (Texas Top Cop Shop, Inc. v. McHenry). The Supreme Court’s...more

White and Williams LLP

Corporate Transparency Act – Supreme Court Weighs In

White and Williams LLP on

December was a busy month of back-and-forth, on again and off again, for the Corporate Transparency Act’s (“CTA”) beneficial ownership information reporting requirements. On Thursday, January 23, 2025, the Supreme Court...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

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act - UPDATED 12-16-2024

Husch Blackwell LLP on

As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) January 1, 2025, beneficial owner information (BOI) reporting deadline. Yet, given the appeal...more

Benesch

FinCEN Confirms Nationwide Pause of Corporate Transparency Act and BOI Reporting Requirements

Benesch on

Entities should continue preparing to comply with BOI reporting requirements. On December 10, 2024, the Financial Crimes Enforcement Network (FinCEN) alerted businesses that, for now, they do not need to report their...more

Jaburg Wilk

Corporate Transparency Act Compliance Deadlines Suspended Nationwide

Jaburg Wilk on

The Corporate Transparency Act (CTA) plays a vital role in protecting the U.S. and international financial systems, as well as people across the country, from illicit finance threats like terrorist financing, drug...more

Hogan Lovells

U.S. District Court suspends enforcement of Corporate Transparency Act (CTA) and FinCEN implementing regulations

Hogan Lovells on

On December 3, 2024, the U.S. District Court for the Eastern District of Texas suspended the enforcement of the U.S. Corporate Transparency Act (“CTA”) and its implementing regulations for “reporting companies” issued by the...more

Wiley Rein LLP

Corporate Transparency Act Update: Government Appeals Nationwide Injunction and Announces No Liability While Injunction Remains in...

Wiley Rein LLP on

On Thursday, December 5, 2024, the U.S. Department of Justice filed notice that it plans to appeal the nationwide injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop v....more

Baker Botts L.L.P.

Federal Court Preliminarily Enjoins Corporate Transparency Act and Implementing Regulations Nationwide

Baker Botts L.L.P. on

On December 3, 2024, Judge Amos L. Mazzant of the U.S. District Court for the Eastern District of Texas entered a nationwide preliminary injunction preventing the federal government from enforcing the Corporate Transparency...more

Vinson & Elkins LLP

FinCEN’s Response to Nationwide Preliminary Injunction Against Enforcement of the Corporate Transparency Act

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As we previously discussed, on December 3, 2024, Judge Amos Mazzant of the U.S. District Court for the Eastern District of Texas issued a memorandum opinion and order granting a nationwide preliminary injunction against the...more

McGlinchey Stafford

And Now We Wait – DOJ Appeals to Fifth Circuit and FinCEN Makes a Statement on CTA Preliminary Injunction

McGlinchey Stafford on

On December 5, 2024, the Department of Justice (DOJ), on behalf of the Department of the Treasury, filed a Notice of Appeal to the Fifth Circuit challenging the nationwide preliminary injunctive relief from compliance with...more

Paul Hastings LLP

Court Pauses Beneficial Ownership Reporting Under the Corporate Transparency Act

Paul Hastings LLP on

On December 3, 2024, the District Court for the Eastern District of Texas issued an order implementing a nationwide preliminary injunction of the Corporate Transparency Act and its enforcement. The court also stayed the...more

Miller Nash LLP

Corporate Transparency Act Update: Nationwide Injunction—FinCEN Responds

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The U.S. Treasury Department, Financial Crimes Enforcement Network (FinCEN) has responded to the nationwide injunction issued last week by a Texas federal district court enjoining the enforcement of the Corporate Transparency...more

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