News & Analysis as of

Corporate Transparency Act Department of Justice (DOJ) Enforcement Actions

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Orrick, Herrington & Sutcliffe LLP

Treasury suspends enforcement of beneficial ownership information reporting for U.S. companies, focuses on foreign entities

On March 2, the Treasury announced it will suspend enforcement of fines or penalties indefinitely for beneficial ownership information (BOI) reporting. This suspension of enforcement will be for U.S. domestic reporting...more

Greenbaum, Rowe, Smith & Davis LLP

Another Urgent Update: Corporate Transparency Act is Again Enforceable with New Deadline for Reporting

We previously reported that on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the Fifth Circuit motion panel’s stay of the Corporate Transparency Act (CTA) of the temporary injunction granted by...more

Bracewell LLP

Corporate Transparency Act Reporting Obligations Effective Again With March 21, 2025, Deadline for Most Reporting Companies

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On February 17, 2025, the US District Court for the Eastern District of Texas (EDTX) in Smith, et. al. v. US Department of the Treasury, et. al., entered an order staying the nationwide injunction on enforcement of the...more

Brooks Pierce

Corporate Transparency Act: March 21, 2025 Reporting Deadline

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Effective February 18, 2025, and until further notice, beneficial ownership information report filings under the Corporate Transparency Act are once again legally required. The deadline for most reporting companies to file...more

Bond Schoeneck & King PLLC

Corporate Transparency Act Filing Requirements Reinstated: U.S. District Court for the Eastern District of Texas Grants Federal...

On Feb. 17, 2025, the U.S. District Court for the Eastern District of Texas (in Smith, et al. v. U.S. Department of the Treasury, et al.) granted the federal government’s motion to stay a nationwide preliminary injunction...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect: March 21 Is the New Deadline to File Beneficial Ownership Reports

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The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Fox Rothschild LLP

Corporate Transparency Act Back in Effect

Fox Rothschild LLP on

The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI). This week, a Texas federal court lifted the last...more

Ruder Ware

Yo-Yo-Yo: CTA is Back

Ruder Ware on

The Corporate Transparency Act (CTA) and its reporting requirements are back in effect. This afternoon, a federal district court in Texas granted the U.S. government’s motion to stay (i.e., pause) the nationwide CTA...more

Kerr Russell

Corporate Transparency Act Enforcement Expected to Resume Following Legal Developments

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While the United States Supreme Court recently lifted one nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Incorporated et al. v. McHenry (formerly Garland),...more

Neal, Gerber & Eisenberg LLP

DOJ Seeks to Reinstate Corporate Transparency Act

On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more

Vinson & Elkins LLP

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

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On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

Dickinson Wright

Supreme Court Stays Fifth Circuit CTA Injunction, But Clarity Remains Elusive

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On Jan. 23, 2025, the United States Supreme Court reinstated a stay on the Fifth Circuit Court of Appeals’ Dec. 26, 2024, decision, which had upheld a lower court’s nationwide injunction blocking enforcement of the Corporate...more

Morgan Lewis

CTA Still On Hold: US Supreme Court Lifts One Injunction, But Another Remains

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The US Supreme Court has granted FinCEN’s request for a stay of the recent nationwide injunction of enforcement of the Corporate Transparency Act (CTA). A separate nationwide injunction, however, remains in place, meaning...more

Foley Hoag LLP

Corporate Transparency Act Remains Subject to Nationwide Preliminary Injunction Despite Supreme Court Ruling

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On January 23, 2025, the U.S. Supreme Court stayed a nationwide preliminary injunction of the Corporate Transparency Act (“CTA”) previously issued by the U.S. Federal District Court for the Eastern District of Texas (Texas...more

Kerr Russell

CTA Enforcement Remains Suspended Amid Ongoing Litigation

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On January 23, 2025, the U.S. Supreme Court granted the U.S. Department of Justice’s request to stay the nationwide injunction that had previously banned enforcement of the Corporate Transparency Act (CTA) and its key...more

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...more

Husch Blackwell LLP

Nationwide Injunction Halts Enforcement of the Corporate Transparency Act -

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As of the posting of this article, reporting companies nationwide do not need to comply with the Corporate Transparency Act’s (CTA) revised beneficial owner information (BOI) reporting deadlines, though the situation may...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

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On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Amundsen Davis LLC

U.S. Supreme Court Provisionally Reinstates the Corporate Transparency Act

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The U.S. Supreme Court issued an order on January 23, 2025, which provisionally reinstates the Corporate Transparency Act (CTA) while a legal challenge to it continues. This brief order, which stayed an injunction against the...more

Paul Hastings LLP

Private Company Report: Fourth Quarter 2024

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This edition of the Private Company Report highlights critical updates and regulatory changes affecting private companies, including a temporary stay on the enforcement of the new beneficial ownership reporting requirements...more

McGuireWoods LLP

DOJ Seeks Supreme Court Review of CTA Injunction

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Another flurry of court activity has further muddied the Corporate Transparency Act (CTA) waters, leaving additional uncertainty about its enforceability. You may recall that on December 26, 2024, the Fifth Circuit...more

Farella Braun + Martel LLP

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Benesch

White Collar Quarterly Report | Q1 2024

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We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2024

The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...more

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