On the heels of a court decision in its favor, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), has issued a statement on its website indicating that the beneficial ownership reporting requirements under the Corporate Transparency Act (CTA) are back in effect, with a new reporting deadline of March 21, 2025. On February 17, Judge Jeremy D. Kernodle of the U.S. District Court for the Eastern District of Texas lifted his previously imposed nationwide injunction on the enforcement of the CTA’s controversial reporting requirements, paving the way for FinCEN to re-commence enforcement efforts. The newly issued deadline predates the oral arguments scheduled for April 1 with respect to a previously issued injunction in the Fifth Circuit Court of Appeals, so businesses that have not yet completed their beneficial ownership interest reports should not rely on relief coming from that case and should thus be prepared to submit reports by March 21. In its statement, FinCEN also indicated, somewhat cryptically, that it will assess its options for further modifying deadlines.
The whiplash-inducing details of the litigation surrounding the CTA are described in our prior Law Alerts on this topic, available here:
Ari Sonneberg specializes in the fields of ERISA and employee benefits. Ari advises and represents clients with respect to design, compliance and all other aspects of qualified and non-qualified employee benefit plans. He has extensive experience in drafting, designing, amending, and restating qualified and non-qualified employee benefit plans and related trusts, including money purchase pension plans, profit sharing plans, 401(k) plans, defined benefit plans, welfare benefit plans, medical expense reimbursement plans, 403(b) plans, and nonqualified deferred compensation plans.
