While the March 21, 2025 filing deadline under the Corporate Transparency Act (the “CTA”) remains in place, the Treasury Department announced on March 2nd that it will not enforce any penalties or fines associated with beneficial ownership reporting under the CTA. Further, any enforcement, penalties, or fines in respect of any domestic companies, U.S. citizens, or their beneficial owners have been suspended. The Financial Crimes Enforcement Network (“FinCEN”) also stated that it is assessing further modifying the beneficial ownership filing deadlines and will provide new guidance, “prioritizing reporting for those entities that pose the most significant national security risks.”
The notice from the Treasury Department comes in the wake of the February 18, 2025 decision by the court in the Eastern District of Texas in Smith v. United States Department of the Treasury which had lifted the only remaining nationwide preliminary injunction on enforcement of the CTA.
It is important to note that the Treasury Department has not announced what will happen to those domestic companies or U.S. citizens who have already provided their beneficial ownership information to FinCEN. The Treasury Department has stated that it is proposing new rulemaking to narrow the scope of the CTA to apply only to foreign companies.
