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In our last update, we reported that the U.S. Supreme Court lifted one nationwide injunction on the Corporate Transparency Act (“CTA”), which subsequently led to the U.S. District Court for the Eastern District of Texas removing a separate nationwide injunction it had previously put in place, effectively allowing the Financial Crimes Enforcement Network (“FinCEN”) to reinstate beneficial ownership information (“BOI”) reporting requirements under the CTA.
Following those decisions, FinCEN set a March 21, 2025, filing deadline for most reporting companies, but also acknowledged that it might further modify deadlines and reporting requirements. Following through on that possibility, FinCEN has now most recently announced that it will not impose any fines, penalties, or enforcement actions against companies that fail to meet the previously announced March 21 deadline.
Instead, FinCEN has stated that no enforcement actions will be taken until an upcoming interim final rule becomes effective. FinCEN has announced that this rule will be published no later than March 21, 2025, and will provide updated BOI reporting deadlines and additional guidance. FinCEN has also indicated its intent to solicit public input on potential revisions to existing reporting requirements as part of a broader effort to minimize regulatory burdens while maintaining the effectiveness of BOI reporting for law enforcement and national security purposes.
It is important to note that this is not a full suspension or repeal of the CTA’s requirements—only a temporary pause on the enforcement of the March 21 deadline while FinCEN finalizes new reporting requirements. Companies should remain prepared for compliance, as updated deadlines and potential modifications to reporting obligations will be announced. For questions on the CTA or how this decision may affect your organization, please contact KWGD.
Written by:
Attorneys Matthew R. Hull and Nathan C. Newcomer
Krugliak, Wilkins, Griffiths & Dougherty Co., L.P.A.
330-497-0700
mhull@kwgd.com, nnewcomer@kwgd.com