Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings. Voluntary Submission is available. We don’t expect FinCEN, in any event, to reinstate the 12/31/2024 deadline because previously, they had already announced the January 13, 2025 grace period.
As such, Voluntary Submission is available and possibly the best route, given the back and forth between the government and the court system. Because the injunction is in place, FinCEN cannot enforce the CTA.
