Category: CTA

Client Alert: Treasury Suspends CTA Enforcement for U.S. Citizens & Domestic Companies

On March 2, 2025, the U.S. Treasury announced a temporary suspension of Corporate Transparency Act (CTA) enforcement for U.S. citizens, domestic reporting companies, and their beneficial owners, and indicated it intends to narrow the CTA’s scope so that the reporting requirements apply only to foreign reporting companies.

Here’s what this means:
🔹Narrowing the Scope of Reporting: The Treasury aims to limit CTA reporting only to foreign reporting companies, potentially eliminating compliance for U.S. businesses.
🔹Enforcement Temporarily Paused: While the CTA’s reporting obligations remain in place, no penalties or fines for noncompliance will be issued at this time.
🔹Upcoming Rule Changes: FinCEN is expected to release an interim final rule by March 21, 2025, extending deadlines and clarifying BOI reporting obligations.

Next Steps for Businesses:
✅ Domestic Companies: If you’ve already filed BOI reports or were preparing to, consider pausing further action until FinCEN provides clarity.
✅ Foreign Companies: Continue preparing BOI reports, given reporting obligations are likely to remain, but consider waiting to file until further guidance is provided by FinCEN.
✅ Stay Alert: More guidance is coming soon— stay tuned for revised reporting requirements and additional enforcement decisions.

We’re tracking developments and will provide updates as FinCEN releases new guidance. Read more here.

For more information on our CTA team, visit their bios here:
Lorren Patterson
Paul-Kalvin Collins
Japera Parker

#CorporateTransparencyAct #CTA #FinCEN #BOI #RegulatoryCompliance #LegalUpdate

Client Alert: “CTA Whiplash: FinCEN Pumps the Brakes on Enforcement—What’s Next?”

Just as companies were gearing up to meet the March 21st deadline for Corporate Transparency Act (CTA) compliance, FinCEN hit the brakes on enforcement. On Thursday, FinCEN announced it will not issue fines, penalties, or take enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports while it works on extending deadlines.

What Just Happened?
• Feb. 17-18 – A federal court lifts the last nationwide injunction, reinstating CTA reporting requirements. In response, FinCEN extends the filing deadline for most companies to March 21, 2025.
• Feb. 27 – FinCEN announces that non-compliance won’t be penalized—for now.

What’s Next?
• By March 21, 2025 – FinCEN expects to issue an interim final rule extending BOI deadlines.
• Later in 2025 – FinCEN plans to revise reporting requirements to reduce the burden on small businesses.

What Does This Mean for You?
• Filing is effectively voluntary (for now). Companies may choose to hold off until clearer guidance is issued.
• Corrections may still be necessary—FinCEN’s pause doesn’t explicitly cover fixing past errors.
• Stay informed—Federal litigation and legislative challenges to the CTA are ongoing.

Buckle up—the CTA ride isn’t over yet. We’re tracking developments and will provide updates as FinCEN releases new guidance. Read more here.

For more information on our CTA team, visit their bios here:
Lorren Patterson
Paul-Kalvin Collins
Japera Parker

#CorporateTransparencyAct #CTA #FinCEN #BOI #RegulatoryCompliance #LegalUpdate

Client Alert: CTA Springs Back into Action – New BOI Report Filing Deadline Set for March 21, 2025

Mark your calendars. After months of legal back and forth, the Corporate Transparency Act (“CTA”) reporting requirements are back in effect, for now, with a new deadline of March 21, 2025.

The U.S. District Court for the Eastern District of Texas lifted its nationwide preliminary injunction, aligning with the Supreme Court of the United States’ decision earlier this year to stay a similar nationwide injunction. Consequently, reporting obligations are back on and FinCEN has extended the filing deadline to March 21, 2025.

Action Steps:
✅ Assess Your Status and Compile Ownership and Control Information: Assess if your entity qualifies as a “reporting company” under the CTA and gather the most up to date ownership and control information for your entity.
✅ Obtain FinCEN IDs or Identifying Information: Collect identifying information for each person who qualifies as a “beneficial owner” under the CTA. Encourage beneficial owners to secure a FinCEN ID to streamline reporting.
✅ Prepare for Submission: Be ready to file initial, updated, or corrected Beneficial Ownership Information (BOI) reports by the March 21 deadline using FinCEN’s E-Filing system.
✅ Stay Informed: Monitor ongoing federal litigation and potential legislative changes affecting CTA requirements.

FinCEN acknowledges that reporting companies may need additional time to meet the March 21 deadline and has stated that if it opts to modify the deadline, an update will be shared before that date. Additionally, in the coming months, FinCEN intends to revise reporting rules to reduce burdens for low-risk entities, including U.S. small businesses, while focusing on entities posing greater national security risks. This may include developing additional reporting exemptions.

Our CTA team will keep you updated on the latest developments. To read the full Client Alert, visit here.

For more information on our CTA team, visit their bios here:
Lorren Patterson
Paul-Kalvin Collins
Japera Parker

#CorporateTransparencyAct #CTA #FinCEN #BusinessCompliance #LegalUpdate

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