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Corporate Transparency Act Update: Treasury Department Suspends Enforcement of CTA for U.S. Companies and Announces Upcoming Rule Changes

Published: March 6, 2025

by Jeanne L. Vance, Josh P. Concepcion

On March 2, 2025, the U.S. Department of the Treasury announced a major shift in its approach to the Corporate Transparency Act (“CTA”). The Treasury Department stated that it will not enforce any penalties or fines related to the CTA’s reporting requirements against U.S. citizens, domestic reporting companies, or their beneficial owners, both under the current deadlines and after forthcoming rule changes take effect. Additionally, the Treasury Department has indicated that it plans to issue a proposed rule that would limit the CTA’s reach to foreign reporting companies only. At this stage, however, no formal rule change has been enacted which means that the original compliance dates and penalties are still current law.

Corporate Transparency Act Update: Nationwide Injunction Still in Place – No BOI Filings Required for Now

Published: January 29, 2025

by Josh P. Concepcion

In a significant update regarding the enforcement of the Corporate Transparency Act (CTA), the Financial Crimes Enforcement Network (FinCEN) has confirmed that companies are not required to file Beneficial Ownership Information (BOI) reports at this time due to an outstanding nationwide injunction. However, reporting companies may continue to voluntarily submit BOI reports.

U.S. Supreme Court Lifts Injunction on Corporate Transparency Act Enforcement; Organizations Obligated to Make BOI Reports

Published: January 24, 2025

by Jeanne L. Vance, Josh P. Concepcion

The Supreme Court of the United States has stayed the nationwide injunction against enforcement of the Corporate Transparency Act (CTA), allowing the government to resume implementation of the law while litigation continues. Therefore, organizations are again required to make beneficial ownership interest reports to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN).