Update: Corporate Transparency Act On Hold

We have previously written about the new Corporate Transparency Act (CTA), a federal law that requires some 20 million businesses to report their beneficial owners (including senior officers) to the Financial Crimes Enforcement Network (FinCEN), a division of the US Department of Treasury. For many companies, the deadline to file is coming up on January 1, 2025.

But on Tuesday, December 3, 2024, a District Court in Texas issued a preliminary injunction finding the CTA unconstitutional and preventing enforcement of the CTA nationwide. (Read the full text of the 79-page order.) FinCEN has filed a notice of appeal to the Fifth Circuit Court of Appeals; and from there it could end up before the US Supreme Court.

FinCEN has issued a statement confirming that the CTA’s filing deadlines have been suspended pending appeal, though reports can still be filed voluntarily. It remains to be seen what will happen to the filing deadlines if the Texas preliminary injunction is voided on appeal. We at PathLight Law will continue to monitor developments.

Meanwhile, reach out to us if you have any questions about your filing obligations.