On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the nation-wide injunction it issued in January of this year in the case of Smith, et al. v. U.S. Department of the Treasury, which injunction had stayed the enforcement of the Corporate Transparency Act (“CTA”) and the reporting obligations that were promulgated under the CTA. The effect of the lifting of the injunction would have been that the original deadlines previously announced by FinCEN, a department of the U.S. Treasury Department, were back in effect, which would have made most entities delinquent in their reporting obligations under the CTA. In a release also dated February 18th, FinCEN noted that it was granting a 30-day extension from February 19, 2025 for companies to file their BOI Reports under the CTA. The release noted certain exceptions in deadlines for certain companies. FinCEN also noted that, during this new filing period, FinCEN will consider further adjustments to deadlines, focusing on entities with the highest national security risks. Additionally, FinCEN noted that it plans to revise the BOI Report filing requirements later this year to ease the burden on low-risk entities, particularly small U.S. businesses.
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