Current Status of the CTA: Suspended
In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing beneficial ownership information reporting rules under the Corporate Transparency Act (CTA).
Further, in anticipation of forthcoming rule changes, the Treasury Department previewed that, following such rule changes, it will not enforce penalties or fines against U.S. citizens, domestic reporting companies, or their beneficial owners, and that the CTA’s reporting requirements will be limited to foreign reporting companies.
Prior to this announcement, a U.S. District Court stayed a previous preliminary injunction and, following such ruling, the CTA reporting deadlines were extended until March 21, 2025. With this latest announcement, the Treasury Department has effectively temporarily exempted all reporting companies from the reporting requirements under the CTA and previewed a permanent exemption for U.S. citizens and domestic reporting companies and their beneficial owners.
What’s Next?
We expect further developments regarding the Treasury Department’s proposed rulemaking to narrow the scope of the CTA reporting rules to foreign reporting companies. Fenwick will continue to provide updates.
