News & Analysis as of

Reporting Requirements Constitutional Challenges Anti-Money Laundering

Bradley Arant Boult Cummings LLP

Will There Be Light? FinCEN’s New Reporting Rule Faces Legal Challenge

The U.S. real estate market has long been a cornerstone of the American dream—a path to stability, investment, and generational wealth. But at the margins, that same market has also provided an opportunity for illicit actors...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

Eversheds Sutherland (US) LLP

And just like that—the Corporate Transparency Act is back!

The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted. The Corporate...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

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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

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

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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

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

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After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

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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

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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

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

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The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...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

Department Of Treasury Letter Evidences CTA Privacy Threat

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As explained in this Alert, the Fifth Circuit Court of Appeals in an abrupt volte-face has reinstated the nationwide injunction against enforcement of the Corporate Transparency Act’s Beneficial Ownership Information...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

PilieroMazza PLLC

Corporate Transparency Act, Part 7: Reporting Requirements Stayed (Again), Voluntary Reporting Allowed

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In the latest twist regarding the Corporate Transparency Act (CTA), the U.S. Court of Appeals for the Fifth Circuit, on December 26, 2024, vacated its own stay of the nationwide preliminary injunction that halted 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

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

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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

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