The Corporate Transparency Act (the “CTA”) has faced yet another major pivot as of Thursday, December 26, 2024: the nationwide injunction of the CTA is in effect once again. This means that the CTA and its Reporting Rule are currently not enforceable and Reporting Companies do not have a duty to file beneficial owner reports.
The Financial Crimes Enforcement Network (“FinCEN”) issued this statement on December 27, 2024: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
While the CTA is enjoined for the moment, Reporting Companies should continue to monitor for updates and be prepared to file if the injunction is overturned.
Please see below for our previous updates on the CTA:
