To Our Clients and Friends:
On December 26, 2024, a different panel of the U.S. Court of
Appeals for the Fifth Circuit issued an order vacating the
Court's December 23, 2024 order, which granted a stay of the
preliminary injunction. Accordingly, as of December 26,
2024, reporting companies are not currently required to file
beneficial ownership information ("BOI")
reports.
This case is still being litigated. Accordingly, legal developments could occur quickly or without warning, so we recommend reporting companies proceed carefully and be prepared to file a report by the required deadline if the preliminary injunction is stayed (again) or overturned on appeal.
If you have any questions about CTA compliance in light of this
update, please contact the GCT attorney with whom you work. GCT
will continue to monitor developments and provide updates as they
become
available.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
