As of December 28, 2024, the enforcement of the Corporate Transparency Act (CTA) is temporarily halted due to a nationwide preliminary injunction issued by the U.S. District Court for the Eastern District of Texas on December 3, 2024.
This injunction has been subject to legal challenges, including a stay by the Fifth Circuit Court of Appeals on December 23, 2024, which was subsequently vacated on December 26, 2024, reinstating the injunction.
Given this legal uncertainty, the Financial Crimes Enforcement Network (FinCEN) has stated that reporting companies are not currently required to file beneficial ownership information and will not face penalties for non-compliance while the injunction remains in effect.
However, FinCEN IS accepting voluntary submissions.
Considering the potential for rapid legal developments, it would be prudent to prepare your beneficial ownership information for submission.
This preparation will enable you to comply promptly if the injunction is lifted and the reporting requirements are reinstated.
Staying informed about the latest legal updates and FinCEN announcements is advisable to ensure timely compliance once the legal situation is resolved.
Recent Developments on the Corporate Transparency Act
Reuters
The Wall Street Journal
Associated Press
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