The Corporate Transparency Act: Spring 2025 Update

Here is an update on the current status of the CTA:

On February 27, 2025, the Financial Crimes Enforcement Network ("FinCEN") announced a suspension of enforcement actions related to the Corporate Transparency Act ("CTA"). https://www.fincen.gov/news/news-releases/fincen-not-issuing-fines-or-penalties-connection-beneficial-ownership

FinCEN stated that no later than March 21, 2025, it intends to issue an interim final rule that extends BOI reporting deadlines. No fines or penalties will be issued, and no enforcement actions will be taken, until such interim final rule becomes effective, and the new relevant due dates in the interim rule have passed.

On March 02, 2025, the U.S. Treasury announced that, no matter the regulations, now or in the future, it will not enforce the CTA against U.S. citizens or domestic reporting companies. https://home.treasury.gov/news/press-releases/sb0038

Instead, it plans to issue proposed rulemaking to narrow the scope of the CTA's requirements to foreign reporting companies only.

Previously, FinCEN had extended the BOI reporting deadline from January 1, 2025 to March 21, 2025. However, with these latest announcements by FinCEN and the Treasury Department, enforcement of the CTA's reporting requirements is once again on hold.

For more background information on the CTA, see our previous article: The Corporate Transparency Act And Its Recent Legal Status

Disclaimer: This update was prepared as of March 18, 2025, and is subject to change. This is only a summary of a complex regulatory system and not legal advice. Direct specific questions regarding the CTA to your attorney.

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