February 20, 2025
By: Kevin Levy and Natali Reyes
The Corporate Transparency Act (CTA) compliance situation continues to develop.
On February 18, 2025, a Texas court lifted its nationwide preliminary injunction prohibiting enforcement of the CTA, which has been in place since early January (with other injunctions in place before then, which have since been reversed as well).
In response, FinCEN issued a statement that the beneficial ownership information requirements under the CTA are once again back in effect, and the filing date for most entities has been extended to March 21, 2025. However, reporting companies that previously qualified for a disaster relief extension, which falls after the new March 21, 2025, deadline, may continue to abide by such disaster relief extension.
FinCEN also announced its intention to further revise the CTA rules, including a commitment to reduce the obligations of certain lower-risk entities, and is assessing options to further modify deadlines over the next 30 days. There has also been legislation introduced in the U.S. House and Senate proposing to extend certain deadlines.
As a reminder, there are potential significant civil and criminal penalties for both companies and individuals who willfully fail to meet their reporting obligations under the CTA in a timely manner.
For more information, please visit the FinCEN website or contact our CTA Committee.
For additional background, please review our prior Insights:
- Corporate Transparency Act Filing Requirements Still in Limbo
- Texas Court Issues Preliminary Injunction Blocking Enforcement of the Corporate Transparency Act Nationwide
- Corporate Transparency Act Filing Deadlines Extended for Hurricane Victims
- Corporate Transparency Act Filing Deadline Fast Approaching for Pre-existing Companies
- Corporate Transparency Act and the End of Hiding in the U.S.
Questions?
Contact GrayRobinson Business Law Section Chair Kevin Levy, Attorney Natali Reyes, or a member of our CTA Committee.