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

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