Corporate Transparency Act Once Again Enforceable

On December 23, 2024, the Fifth Circuit Court of Appeals ("Appeals Court") lifted the nationwide injunction that blocked the enforceability of the Corporate Transparency Act ("CTA"). The Appeals Court found "the government has made a strong showing that it is likely to succeed on the merits in defending the CTA's constitutionality." As such, companies not otherwise exempt from the filing requirement are once again mandated to provide certain identifying information about their beneficial owners to the Financial Crimes Enforcement Network ("FinCEN").

Following the Appeals Court's decision, FinCEN extended the filing deadlines as follows:

• Reporting companies created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information ("BOI") reports with FinCEN;