NEW UPDATE - Nationwide Injunction on CTA Reporting Requirements Reinstated – Enforcement Halted Once Again

As of December 26, 2024, the Fifth Circuit Court of Appeals has reinstated the nationwide injunction against the Corporate Transparency Act (CTA) reporting requirements. This means that Reporting Companies are no longer required to file their initial Beneficial Ownership Information (BOI) reports until further notice. 

In this latest development, the Fifth Circuit vacated a December 23, 2024 order that had temporarily reinstated the CTA’s compliance deadlines. The court clarified that this move was to preserve the constitutional status quo while it deliberates the case’s substantive arguments. The appeal is currently being reviewed on an expedited basis. 

At this time, the Financial Crimes Enforcement Network (FinCEN) has not issued a formal response. The situation remains fluid, and further updates are expected soon. 

We’re closely monitoring these developments to ensure you remain informed. As always, we recommend consulting with your compliance advisors to understand how these changes may impact your business entities. 

Stay tuned for more updates as they unfold!