CTA Filing Obligations Back On

The last remaining nationwide injunction pausing obligatory reporting under the Corporate Transparency Act (CTA) and the related regulations (31 C.F.R. § 1010.380) was lifted on February 17, 2025. Absent further administrative or Congressional action, reporting companies which have not yet filed beneficial ownership information with the U.S. Treasury's Financial Crimes and Enforcement Network (FinCEN) must do so by March 21, 2025.

Enforcement of the CTA has been subject to various court challenges. In particular, two lower district courts in Texas had separately issued nationwide injunctions suspending required reporting under the CTA. One of those cases, McHenry v. Texas Top Cop Shop, Inc., wound its way to the U.S. Supreme Court, which, on January 23, 2025, stayed the lower courts' nationwide injunction. McHenry v. Texas Top Cop Shop, Inc. (No. 24A653, 604 U.S. _______, 2025 WL 272062, at *1). On February 17, 2025, and in light of the Supreme Court's ruling in Tex