In an unpublished order issued on December 23, 2024, the Fifth Circuit granted the Financial Crimes Enforcement Network’s (“FinCEN”) emergency motion for a stay of the nationwide preliminary injunction that blocked enforcement of the Corporate Transparency Act (“CTA”) pending appeal in the case of Texas Top Cop Shop, Inc. v. Garland. The Fifth Circuit’s stay of the preliminary injunction means that the nationwide injunction blocking enforcement of the CTA is no longer valid. Based on its court filings, FinCEN expects reporting companies formed prior to January 1, 2024, to file their initial beneficial ownership information report no later than the January 1, 2025 deadline to comply with the CTA.
Our team will continue to monitor developments surrounding the CTA (including any appeal by plaintiffs to the U.S. Supreme Court) and will provide updates as they occur.
