Mandatory CTA Reporting Is On! (Again)

As I’ve written previously, the Financial Crimes Enforcement Network (FinCEN) tabled enforcement of the Corporate Transparency Act reporting requirements in light of nationwide injunctions issued by two federal district courts.

In January, the US Supreme Court vacated the injunction in one of those cases pending resolution of an appeal (Texas Top Cop Shop v. Garland), but left the injunction in the second case (Smith v Treasury) in place. On February 15, 2025, FinCEN filed a Notice of Appeal in the Smith case requesting a stay of the injunction pending appeal. The district court stayed the injunction on February 17, 2025.

As a result, the CTA reporting requirements are once again enforceable pending resolution of the various federal appeals.

FinCEN issued guidance this week notifying the new deadline to report their beneficial ownership information (BOI) to FinCEN is March 21, 2025. This deadline applies to all companies subject to the CTA (LLCs, corporations, and similar entities) formed before January 1, 2025. Companies formed after 2024 are required to file their BOI report within 90 days of formation.

BOI reporting is no longer voluntary. We will continue to monitor developments and update information for you as they arise.

For questions regarding your responsibility regarding BOI reporting for your business entity, please contact us.