Corporate Transparency Act Reinstated – New Deadline for Compliance

Enforcement of the Corporate Transparency Act (the “CTA”) is once again in effect after a recent court decision. The new deadline for compliance is March 21, 2025 for most reporting companies, subject to any further guidance.

On February 18, 2025, a U.S. District Court for the Eastern District of Texas, Tyler Division, stayed a nationwide injunction against enforcement of the CTA it had previously issued in Smith v. United States Department of the Treasury.

In response to the stay of the Smith injunction, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) promptly issued an alert titled “Ongoing Litigation . . . Corporate Transparency Act reporting requirements back in effect” on its website,  in which it stated that the new deadline for filing any required initial, updated, and/or corrected beneficial ownership information reports (“BOIRs”) is March 21, 2025, unless the reporting company was previously given a later deadline.

FinCEN also indicated that it continues to assess its options to further modify deadlines.

Stoel Rives lawyers are available to assist in determining whether an entity is exempt and who its beneficial owners are for reporting purposes, but we will not be affirmatively advising clients with respect to the CTA unless specifically engaged to do so. We will also not be able to submit BOIRs on your behalf. Please reach out to your Stoel Rives contact if you have any questions or need assistance.