On February 18, 2025, the U.S. District Court for the Eastern
District of Texas in Smith, et al. v. U.S. Department of the
Treasury, et al., 6:24-cv-00336 (E.D. Tex.) held that
beneficial ownership information ("BOI") reporting
requirements under the Corporate Transparency Act (the
"CTA") were back in effect. Accordingly, the Treasury
Department's Financial Crimes Enforcement Network
("FinCEN") extended the reporting deadline until March
21, 2025.
However, FinCEN has once again adjusted its stance on reporting
requirements. On February 27, 2025, FinCEN issued a press release
announcing that it will not be issuing any fines or penalties
against any companies who fail to comply with the current reporting
deadlines. FinCEN anticipates issuing a final rule extending BOI
reporting deadlines and providing guidance and clarity no later
than March 21, 2025.
