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ARTICLE · 17 JANUARY 2025

CTA Enforcement On Hold

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

Kelley Drye & Warren LLP

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Enforcement of the Corporate Transparency Act (the ​"CTA") reporting requirements was once again put on hold over the holidays. On December 3, 2024, the U.S. District Court for the Eastern District of Texas...

United StatesCorporate/Commercial Law
Wendy A. Clarke
Wendy A. Clarke
Jeffrey Hunter
Jeffrey Hunter
Matthew Luzadder
Matthew Luzadder
Aaron Rosenfeld
Aaron Rosenfeld
Matthew Weir
Matthew Weir

Enforcement of the Corporate Transparency Act (the "CTA") reporting requirements was once again put on hold over the holidays. On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued an order enjoining the nationwide enforcement of the CTA in Texas Top Cop Shop vs. Garland. Following an appeal by the government in the Fifth Circuit, on December 23, 2024 a motions panel granted a stay of the nationwide injunction pending appeal. Consequently, CTA compliance was back in effect with FinCEN granting extended reporting deadlines. On December 26, 2024, however, the Fifth Circuit vacated part of its December 23, 2024 order which once again halted CTA enforcement.

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