Update On Corporate Transparency Act Enforcement

As of December 26, 2024, reporting companies are not required to submit beneficial ownership information reports ("BOIRs") with FinCEN, nor will they face penalties for failing to do so while the injunction remains in place. However, businesses can still voluntarily file beneficial ownership reports.

On December 23, 2024, a panel from the U.S. Court of Appeals for the Fifth Circuit issued a temporary stay of the United States District Court for the Eastern District of Texas' preliminary injunction against enforcement of the Corporate Transparency Act and its Reporting Rule in the Texas Top Cop Shop case, pending the resolution of the Treasury Department's appeal. As a result, the Treasury Department extended reporting deadlines to provide businesses with more time to comply. However, just a few days later, on December 26, 2024, a different panel from the U.S. Court of Appeals for the Fifth Circuit vacated the stay order, putting the injunction back in effect.