News & Analysis as of

FinCEN Stays Appeals

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Reporting Requirements Are Back: New March 21 Deadline

In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...more

BakerHostetler

CTA Back in Effect; New Reporting Deadline of March 21

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On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more

Holland & Knight LLP

Corporate Transparency Act: Government Appeals Smith Case, Seeks Reporting Rule Reinstatement

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Here are the latest developments in the ongoing Corporate Transparency Act (CTA) saga...more

BCLP

FinCEN Provides Guidance to Reporting Companies in Wake of Second Appeal to Fifth Circuit

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As previously reported, the Supreme Court has already considered on an emergency basis whether to stay Corporate Transparency Act (“CTA”) enforcement deadlines. In that case, McHenry v. Texas Top Cop Shop, Inc., No. 24A653,...more

Neal, Gerber & Eisenberg LLP

DOJ Seeks to Reinstate Corporate Transparency Act

On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more

Pierce Atwood LLP

It Lives: Trump Administration Defends Corporate Transparency Act; May Modify its Application

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On February 5, 2025, the Trump administration added a new chapter to the saga that has been implementation of the Corporate Transparency Act (CTA), filing a notice of appeal and motion for stay against an Eastern District of...more

IR Global

Beneficial Ownership Reporting – To File or Not to File?

IR Global on

Considering conflicting rulings, businesses remain understandably confused about whether to file their mandated Beneficial Ownership Reports with FinCen. As of this writing, the answer remains that businesses may file but are...more

King & Spalding

CTA Compliance Stay Continues Despite Supreme Court Lifting Nationwide Injunction; FinCEN Recognizes Separate District Court Stay...

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On January 23, 2025, the U.S. Supreme Court granted the government’s motion to lift the nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Texas Top Cop Shop v. McHenry (formerly, Texas Top...more

Snell & Wilmer

Another Twist for the Ongoing Corporate Transparency Act Saga: The Supreme Court Provides a Lifeline

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On Thursday, January 23, 2025, in an 8-1 decision, the U.S. Supreme Court stayed one of the two nationwide injunctions of the Corporate Transparency Act (CTA) pending the conclusion of the Fifth Circuit appeal and any...more

Dickinson Wright

Supreme Court Stays Fifth Circuit CTA Injunction, But Clarity Remains Elusive

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On Jan. 23, 2025, the United States Supreme Court reinstated a stay on the Fifth Circuit Court of Appeals’ Dec. 26, 2024, decision, which had upheld a lower court’s nationwide injunction blocking enforcement of the Corporate...more

Holland & Knight LLP

Supreme Court Stays CTA Injunction in Texas Top Cop Shop Case, but CTA Reporting Still on Hold

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In the Texas Top Cop Shop case, the U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued an injunction that deferred all reporting requirements under the Corporate Transparency Act (CTA). (See Holland...more

Morgan Lewis

CTA Still On Hold: US Supreme Court Lifts One Injunction, But Another Remains

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The US Supreme Court has granted FinCEN’s request for a stay of the recent nationwide injunction of enforcement of the Corporate Transparency Act (CTA). A separate nationwide injunction, however, remains in place, meaning...more

Morrison & Foerster LLP

The Ping-Pong Continues – But CTA Is Still on Hold

On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more

Cozen O'Connor

A CTA Injunction Remains Despite Supreme Court Stay

Cozen O'Connor on

On January 23, 2025, the U.S. Supreme Court stayed the injunction issued by the Fifth Circuit Court of Appeals in the case of Texas Top Cop Shop, Inc. v. Garland, et al. Case No. 4:24-cv-478 (E.D. Tex.) (Texas Top Cop Case)....more

Moore & Van Allen PLLC

Corporate Transparency Act Reporting Obligations Remain Paused Despite Supreme Court Order

Moore & Van Allen PLLC on

On January 23, 2025, the United States Supreme Court ruled on McHenry v. Texas Top Cop Shop, Inc., granting the Government’s application to stay the injunction of the Corporate Transparency Act (“CTA”) initially ordered by...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

Husch Blackwell LLP on

As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines, though the situation may...more

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

Cole Schotz on

Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Hinshaw & Culbertson LLP

UPDATE: SCOTUS Stayed a CTA Injunction Under the "Texas Top Cop Shop" Action, BUT the CTA is Still NOT Back in Effect

In the latest twist on the back-and-forth CTA battle, on January 23, 2025, the Supreme Court of the United States (SCOTUS) once again stayed (i.e., suspended the effect of) the nationwide preliminary injunction against...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

BakerHostetler

CTA Still on Hold, Despite Supreme Court Decision

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On Jan. 23, the Supreme Court granted the U.S. government’s application to immediately stay the nationwide CTA injunction issued last month by a federal district court in the Eastern District of Texas. See Texas Top Cop Shop,...more

Tucker Arensberg, P.C.

Update: Despite U.S. Supreme Court Decision, Enforcement of the Corporate Transparency Act (“CTA”) is Still On Hold

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On January 23, 2025, the U.S. Supreme Court lifted an injunction that had blocked enforcement of the CTA and its regulations, as originally issued by the U.S. District Court for the Eastern District of Texas on December 3,...more

Venable LLP

Corporate Transparency Act Update: Despite Supreme Court Order, a Different Injunction Keeps the CTA at Bay - For the Time Being

Venable LLP on

All eyes were focused on how the U.S. Supreme Court (SCOTUS) would respond to the application for stay filed by the federal government on New Year's Eve seeking a stay of the preliminary nationwide injunction issued by a...more

BCLP

SCOTUS Stays Nationwide Injunction of the CTA; But Different District Court Nationwide Stay of Reporting Deadline Still in Effect...

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As previously reported, on December 31, 2024, the government filed an application in the Supreme Court of the United States to stay or narrow the Fifth Circuit’s preliminary nationwide injunction halting the Corporate...more

Proskauer Rose LLP

Round and Round We Go: Corporate Transparency Act Remains Stayed for Now, Despite U.S. Supreme Court Ruling

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On January 23, 2025, the U.S. Supreme Court ruled that the federal government may enforce the Corporate Transparency Act (“CTA”) while the Fifth Circuit continues to review a constitutional challenge to the law. Previously,...more

Allen Matkins

The CTA Is Dealt Another Blow

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As has been widely reported, U.S. District Court Judge Amos L. Mazzant in early December of last year preliminarily enjoined the CTA and its implementing regulations.  Texas Top Cop Shop, Inc. v. Garland, 2024 WL 5049220...more

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