News & Analysis as of

Preliminary Injunctions U.S. Treasury

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

Orrick, Herrington & Sutcliffe LLP

Fourth Circuit grants stay pending appeal in federal privacy case involving unions and individuals

On April 7, the U.S. Court of Appeals for the Fourth Circuit entered an order staying a district court’s preliminary injunction pending appeal, and denied a request for an initial hearing en banc. The plaintiffs, constituting...more

Flaster Greenberg PC

Corporate Transparency Act Update - FinCEN Interim Rule

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On March 21, FinCEN issued an interim rule that implements the reduced scope of the Corporate Transparency Act (“CTA”) previously announced on March 2....more

Flaster Greenberg PC

Corporate Transparency Act Updates - March 2025

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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

Robinson+Cole Data Privacy + Security Insider

DOGE Blocked from Access to Department of Treasury Payment Systems

On February 21, 2025, a federal district court judge from the Southern District of New York issued a preliminary injunction against the Department of Government Efficiency’s (DOGE), access to Treasury Department payment...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

Butler Snow LLP

The Corporate Transparency Act is Back

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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

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

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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

Flaster Greenberg PC

Corporate Transparency Act Updates - February 2025

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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

Kelley Drye & Warren LLP

FinCEN Reinstates CTA Reporting Obligations

On February 18, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are...more

Foley Hoag LLP

Corporate Transparency Act Revived After Last Remaining Nationwide Preliminary Injunction is Lifted - Reporting Deadlines Extended

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On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide preliminary injunction of the CTA in the Smith case. This follows a decision on January 23, 2025, by...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

Maynard Nexsen

Must File CTA Reports by March 21, 2025

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On February 17, 2025, Judge Jeremy D. Kernodle of the U.S. District Court for the Eastern District of Texas stayed the final remaining nationwide preliminary injunction that had temporarily blocked enforcement of the...more

Dorsey & Whitney LLP

FinCEN Confirms New CTA Filing Deadline - But Congress Looks to Push Deadlines For Some Reporting Entities to 2026

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On February 18, 2025, in a widely expected decision, the Eastern District of Texas, in the case of Smith v. United States Dep't of the Treasury, 2025 WL 41924 (E.D. Tex.), and following the decision of the U.S. Supreme Court...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

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: Injuction Lifted - Corporate Transparency Act Back in Effect

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

Orrick, Herrington & Sutcliffe LLP

U.S. SDNY clarifies its temporary restraining order blocking political appointees’ access to Treasury payment systems

On February 11, a federal judge from the U.S. SDNY granted in part and denied in part an emergency motion by DOJ contesting a temporary restraining order (TRO) granted on February 8 that restricted political appointees’...more

Orrick, Herrington & Sutcliffe LLP

U.S. SDNY prohibits DOGE from accessing Treasury Department payment systems and records

On February 8, the U.S. SDNY temporarily blocked DOGE from accessing payment systems, payment records and other data systems operated by the Treasury Department’s Bureau of Fiscal Services (Treasury)....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

Dorsey & Whitney LLP

U.S. Government Appeals CTA Injunction - But Changes to Reporting Requirements May Be On The Horizon

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As we previously reported, on January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to...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

McGlinchey Stafford

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

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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

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