On March 2, 2025, the U.S. Department of the Treasury announced that it intends to suspend enforcement of the Corporate Transparency Act (CTA), and its Reporting Rule, against U.S. citizens and domestic reporting companies. This follows a decision posted last week by FinCEN stating that it will not impose fines or penalties for failure to file Beneficial Ownership Information (BOI) reports by the current deadlines. FinCEN previously stated that it would issue an interim final rule no later than March 21, 2025. FinCEN also intends to follow the more formal notice of the proposed rulemaking process and solicit public comment on potential revisions to existing BOI reporting requirements.
In its Sunday news release, the Treasury Department announced that it intends to issue a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Penalties or fines will not be enforced against U.S. citizens or domestic reporting companies based on a failure to comply with both the existing BOI Reporting Rule and the forthcoming interim rule change that FinCEN intends to implement on or before March 21st. As of now, U.S. entities will not be penalized for failure to file BOI reports with FinCEN.
There are still several lawsuits moving through the legal process, and it is anticipated that additional lawsuits could be filed to force the Trump Administration to comply with the CTA. Our attorneys continue to monitor these developments and will provide updates as they become available. If you have any CTA compliance questions, please contact your Dinsmore attorney.
