In a release dated March 2, 2025, the Treasury Department has indicated that all enforcement of the Corporate Transparency Act (the “CTA”)[1] against United States citizens and domestic reporting companies will be suspended, pending issuance of a proposed rule to limit the applicability of CTA to foreign reporting companies only.[2] For this purpose, domestic reporting companies should include any legal entity formed in any U.S. jurisdiction.
Williams Mullen will continue to monitor any proposed rules and the impact of subsequent actions by the courts and any ensuing appeals along with FinCEN’s implementation of the CTA. We will provide updates and alerts when warranted.
[1] The CTA was enacted into law on January 1, 2021, as part of the Anti-Money Laundering Act of 2020. See, William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, Pub. L. 116-283, 134 Stat. 3388 §§ 6001-6511 (2020).
[2] Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies, March 2, 2025, see here.
