On December 26, 2024, the U.S. Circuit Court of Appeals for the Fifth Circuit reinstated the injunction halting enforcement of the Corporate Transparency Act (CTA), quickly changing the compliance obligations for reporting companies nationwide. As a result, neither beneficial ownership reporting nor updating already-filed reports is required at this time.
As reflected on the Financial Crimes Enforcement Network (FinCEN) website: FinCEN is complying with—and will continue to comply with—the district court's order as long as it remains in effect. As a result, reporting companies are not currently required to file beneficial ownership information with FinCEN. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.
The situation remains fluid, and potential reporting companies should stay abreast of the latest developments in the event reporting obligations come back into effect.
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.