Corporate Transparency Act Reporting Restart

Beneficial Ownership Information ("BOI") reporting obligations under the Corporate Transparency Act ("CTA") are back in effect. On February 17, 2025, a Texas federal judge lifted the stay he had ordered on January 7, 2025, in Smith v. U.S. Department of the Treasury, which had prevented the Government from enforcing BOI reporting requirements on a nationwide basis.

On February 18, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department ("FinCEN") issued a notice that announced the following updates:

1. Unless subject to a later deadline, the new deadline to file an initial, updated and/or corrected BOI report with FinCEN is now March 21, 2025.
2. Before March 21, 2025, FinCEN may further modify deadlines for entities that do not pose significant national security risks. If FinCEN does so, it will provide yet another update "recognizing that reporting companies may need additional time to comply."