CTA Injunction Reinstated – Reporting Requirements on Hold...AGAIN!

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the district court’s preliminary injunction in Texas Top Cop Shop, Inc., et al. ?v. Garland, et al. As a result, the requirement to file Beneficial Ownership Information (BOI) under the Corporate Transparency Act (CTA) is now on hold until the merits panel can fully consider the government’s appeal. For information on the initial suspension of the CTA, see our December 4, 2024 alert HERE.

The Financial Crimes Enforcement Network (FinCEN) has extended some relief by shifting the compliance deadline for certain filings from January 1, 2025, to January 13, 2025. Millions of small businesses and corporate entities across the U.S. must act quickly to comply with the CTA requirements to avoid significant penalties.

What Does This Mean for Your Business?

• Filing Deadlines Suspended: Though the obligation to file BOI under the CTA has been suspended, FinCEN continues to accept voluntary submissions.
• Our Recommendation: Considering the rapidly evolving landscape, businesses should discuss voluntary reporting with their legal counsel while remaining prepared to file if the injunction is lifted.

If you have questions or concerns regarding these changes, contact Jason Lederman at [email protected] or 917.639.5121.