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Corporate Transparency Act Regulatory Requirements Regulatory Agenda

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

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Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Otten Johnson Robinson Neff + Ragonetti PC

A Continuing Saga of CTA Uncertainty

On February 27, 2025, FinCEN published guidance related to the Corporate Transparency Act (the “CTA”) taking the position that it would not “issue any fines or penalties or take any other enforcement actions against any...more

Conyers

Cayman Islands: Legitimate Interest Access of Beneficial Ownership

Conyers on

The Beneficial Ownership Transparency (Legitimate Interest Access) Regulations, 2024 commenced on 28 February 2025. Under these Regulations, the Cayman Islands Registrar (the “Registrar”) may provide access to the information...more

Ward and Smith, P.A.

Corporate Transparency Act Enforcement Suspended Once Again!

Ward and Smith, P.A. on

In a press release, Treasury officials confirmed they would not impose fines on U.S. citizens or domestic reporting companies, effectively pausing the reporting obligations for the time being.  Under the original CTA...more

Verrill

Indefinite Suspension of CTA Filing Obligations (For Now)

Verrill on

On March 2, 2025 the U.S. Treasury Department laid waste to about a million law firm postings about the Corporate Transparency Act, announcing that Treasury now intends to propose fundamental changes to the CTA Rule and that...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Announces Changes to the BOI Reporting Requirements Under the Corporate Transparency Act

On March 2, 2025, the Department of Treasury confirmed in a press release that it will not enforce any penalties or fines associated with the BOI reporting requirements under the existing regulatory deadlines...more

White and Williams LLP

Latest Corporate Transparency Act Update from FinCEN: Enforcement Paused, For Now

Stay tuned – another shoe is likely to drop from Washington D.C. on the CTA (“Corporate Transparency Act”) in the next three weeks. As we previously reported on February 18, 2025, the U.S. District Court for the Eastern...more

Shipkevich PLLC

U.S. Treasury Department Announces Suspension of BOI Reporting Penalties for U.S. Parties

Shipkevich PLLC on

On February 19, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that most reporting companies under the Corporate Transparency Act (“CTA”) must now submit their Beneficial Ownership Information (“BOI”)...more

Buckingham, Doolittle & Burroughs, LLC

FinCEN Temporarily Pauses Enforcement of Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not impose fines, penalties, or other enforcement actions against companies for failing to file or update beneficial ownership...more

Perkins Coie

Corporate Transparency Act: Filing Requirements Once Again Voluntary – FinCEN Announces No Enforcement Action for Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Will Not Enforce the CTA Until Interim Rule is Effective

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced that it will not issue any fines or penalties or initiate any other enforcement action against companies that do not file or update...more

Miller & Martin PLLC

The Corporate Transparency Act: FinCEN Not Issuing Fines or Penalties in Connection with March 21 Deadline

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As an update to our February 21 article, yesterday FinCEN announced that it “will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial...more

McGlinchey Stafford

FinCEN Announces No Penalties for BOI Reporting Failures

McGlinchey Stafford on

On February 27, 2025, FinCEN announced “it will not issue any fines or penalties or take any other enforcement actions against companies based on any failure to file or update beneficial ownership information (BOI) reports...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Beneficial Ownership Information (BOI) Reporting Requirements are Back

On February 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., stayed (lifted) the injunction blocking the enforcement of the Corporate Transparency...more

Shipkevich PLLC

BOI Reporting Back in Effect: Compliance Required by March 21, 2025

Shipkevich PLLC on

On February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that most reporting companies under the Corporate Transparency Act (CTA) must now submit their Beneficial Ownership Information (BOI) reports...more

Miller & Martin PLLC

The Corporate Transparency Act is Back On (For Now)

Miller & Martin PLLC on

The beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA) have been reinstated, and are, once again, mandatory after a Texas federal district court judge’s order on Tuesday,...more

Tonkon Torp LLP

Corporate Transparency Act – BOI Report Filings Mandatory Again

Tonkon Torp LLP on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued an Order in the Smith case lifting the preliminary injunction against enforcement of the CTA. Therefore, BOI Report filings are once again...more

Epstein Becker & Green

CTA Reporting Restored: FinCEN Extends Filing Deadlines and Signals Revisions to Reporting Requirements After Federal Court Lifts...

Epstein Becker & Green on

On February 18, 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., 6:24-cv-00336 (E.D. Tex), lifted its order staying the Financial Crimes Enforcement...more

ArentFox Schiff

The CTA Strikes Back

ArentFox Schiff on

Following a cascade of developments, the Corporate Transparency Act (CTA) is back, but with some potential changes on the horizon. Most reporting companies that have not yet filed all required reports under the CTA should...more

Cozen O'Connor

Latest CTA Injunction Stayed

Cozen O'Connor on

On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction it previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (Smith case)....more

Kerr Russell

CTA Enforcement Reinstated with New Compliance Deadlines

Kerr Russell on

The U.S. District Court for the Eastern District of Texas has stayed the last remaining nationwide injunction against enforcement of the Corporate Transparency Act (CTA) in Smith v. U.S. Department of the Treasury....more

McGlinchey Stafford

CTA’s Beneficial Ownership Reporting Requirement Resumes – At Least for Now

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As the saga of on-again-off-again requirements continues to unfold, FinCEN’s Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have undergone significant changes due to...more

Allen Matkins

A Clearly Rattled Delaware Contemplates Significant Changes To Its Corporations Code

Allen Matkins on

On Monday, Delaware State Senator Bryan Townsend introduced Senate Bill 21 which would, among other things, statutorily define "controlling stockholder" and substantially change the rules governing the "cleansing" of...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Says Reporting Obligations Remain On Hold

Last Friday, the United States Supreme Court lifted a nationwide injunction originally issued by the U.S. District Court for the Eastern District of Texas (and later upheld by the Fifth Circuit Court of Appeals) in Texas Top...more

McGlinchey Stafford

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

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The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more

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