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FinCEN Eliminates CTA Compliance for U.S. Corporate Entities and U.S. Persons – Limiting Compliance to Foreign Reporting Companies

On Friday, March 21, 2025, the United States Financial Crimes Enforcement Network (“FinCEN”) issued for publication in the Federal Register an “interim final rule” (the “Revised Rule”) that effectively exempts all domestic...more

U.S. Treasury Abandons the CTA For All Entities Except “Foreign Reporting Companies”

As we previously announced, last week FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for...more

FinCEN Halts Enforcement of CTA (again!) - A Promised Future Rulemaking Will Reset Compliance Obligations

Having only announced its extended March 21, 2025 deadline to file beneficial ownership information reports under the Corporate Transparency Act (“CTA”) last week, on February 27, 2025, FinCEN confirmed that it would “not...more

FinCEN Confirms New CTA Filing Deadline - But Congress Looks to Push Deadlines For Some Reporting Entities to 2026

On February 18, 2025, in a widely expected decision, the Eastern District of Texas, in the case of Smith v. United States Dep't of the Treasury, 2025 WL 41924 (E.D. Tex.), and following the decision of the U.S. Supreme Court...more

U.S. Government Appeals CTA Injunction - But Changes to Reporting Requirements May Be On The Horizon

As we previously reported, on January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to...more

SCOTUS Overturns One CTA Nationwide Injunction - but Reporting Requirements Still Paused…

On January 23, 2025, the Supreme Court of the United States ruled in favor of the U.S. government in relation to the Corporate Transparency Act (“CTA”) – granting an emergency application to overturn the nationwide...more

CTA Compliance Paused Yet Again - Federal Appeals Court Reinstates Temporary Nationwide Injunction

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Texas Top Cop...more

FinCEN Sets Revised CTA Filing Deadlines After Federal Appeals Court Overrules Temporary Nationwide Injunction

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the government’s emergency motion and stayed the temporary nationwide injunction that prohibited enforcement of the Corporate Transparency...more

FinCEN Responds to Temporary Injunction Halting Enforcement of the Corporate Transparency Act

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against 31 U.S.C. § 5336 and the enforcement of the beneficial ownership information reporting rule...more

Department of Justice Appeals Temporary Injunction Halting Enforcement of the Corporate Transparency Act

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against 31 U.S.C. § 5336 and the enforcement of the beneficial ownership information reporting rule...more

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