Corporate Transparency Act

The CTA lives on . . . barely.

As anticipated, on March 26, 2025, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule that significantly narrows the scope of the Corporate Transparency Act (CTA) to foreign owners of foreign companies, leaving domestic reporting companies and U.S. persons spared from further action under the CTA.

On March 2, 2025, the Treasury Department had announced the suspension of the enforcement of the CTA against U.S. citizens and domestic reporting companies along with its plans to remove the requirement for U.S. companies and U.S. citizens to report beneficial ownership information (BOI) to FinCEN under the CTA. Accordingly, many U.S. companies and U.S. citizens were in a standstill until the Treasury Department released the interim final rule.