As a result of a February 17, 2025 decision by the U.S. District
Court for the Eastern District of Texas in Smith, et al. v.
U.S. Department of the Treasury, et al., the beneficial
ownership information (BOI) reporting requirements under the
Corporate Transparency Act (CTA) are once again back in effect.
The Financial Enforcement Crimes Network (FinCEN) has extended
the deadline for filing initial, corrected, and updated reports
under the CTA to March 21, 2025. If a reporting company currently
has a filing deadline after March 21, 2025, because of, among other
things, FinCEN's earlier hurricane disaster reporting relief,
that later deadline will continue to apply.
However, this is certainly not the end of the story. In
providing this extension, FinCEN stated that during this 30-day
extension, it will assess its options to further modify deadlines
while prioritizing reporting for those entities that pose the most
significant national security risks.
