The Financial Crimes Enforcement Network (FinCEN) has announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect and the new deadline for most businesses to report is March 21, 2025.
While businesses should be prepared to comply with this new deadline, FinCEN has noted that it plans to “assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks”. The agency has not made clear which businesses pose significant national security risks and plans to revise the BOI reporting rule “to reduce burden for lower-risk entities, including many U.S. small businesses”.
While most businesses subject to the CTA are now subject to the new March 21, 2025, deadline, certain businesses, such as those that qualify for certain disaster relief, have later deadlines.
FinCEN’s announcement comes in the wake of a recent court decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.) granting the government’s motion to stay the nationwide injunction of the CTA. This decision is just the latest in a tumultuous legal battle over the CTA. Please see below for our previous updates on the CTA:
- October 4, 2023 – The Corporate Transparency Act: Will it Impact You?
- December 28, 2023 – FinCEN Issues Update to Corporate Transparency Act
- November 19, 2024 – FinCEN Engages in Outreach as CTA Deadline Looms
- December 5, 2024 – Upset in the 11th Hour: Corporate Transparency Act Halted, for Now
- December 10, 2024 – CTA Update: U.S. Government Appeals Injunction & FinCEN Issues Guidance
- December 26, 2024 – Corporate Transparency Act Injunction Lifted, Deadline to File Extended
- December 27, 2024 – CTA Reporting Paused—Again!
- January 24, 2025 – SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause
