On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide preliminary injunction against the Corporate Transparency Act (CTA) that it had previously issued in Smith, et al. v. United States Department of the Treasury, et al. As a result, the reporting requirements of the CTA are once again in effect. In response to this ruling, the Financial Crimes Enforcement Network (FinCEN) has extended the reporting deadline for the vast majority of reporting companies to March 21, 2025.
FinCEN has also indicated that it may further adjust deadlines, prioritizing reporting for those entities that pose the most significant national security risks. Additionally, Congress is currently considering two bills that would extend the deadline for entities formed before January 1, 2024, to comply with the CTA to January 1, 2026. Given the ongoing uncertainty surrounding the CTA, we recommend that reporting companies prepare to make their CTA filings on or before the current March 21 deadline.
Attorneys at Wolfson Bolton Kochis PLLC are closely monitoring developments related to the CTA’s implementation and are available to assist with CTA compliance. Please contact Amy H. Smith ([email protected]) for more information.
