On February 18, 2025, the final court order[1] blocking reporting under the Corporate Transparency Act (CTA) was lifted. Thus, the CTA’s reporting requirements are back in effect, and the new reporting deadline for most reporting companies is March 21, 2025; however, FinCEN has announced that no penalties or fines will currently be enforced for not reporting. Please visit this link to access Parts 1-8 in this series.
Although reporting requirements are back in effect, penalties and fines will not be enforced for the current March 21 reporting deadline. No later than March 21, 2025, FinCEN intends to issue an interim final rule extending the reporting deadlines and providing new guidance and clarity. Further, the Treasury Department separately stated that it may revise the reporting requirements under the CTA in order to narrow the scope of reporting to solely apply to foreign reporting companies. The Treasury Department also does not currently intend to enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the new rule takes effect.
While there is currently a reporting deadline under the CTA and companies are still expected to file, FinCEN has stated no enforcement actions will be taken until the interim final rule becomes effective and the new due dates have passed. Reporting companies should therefore decide whether they still want to report, or wait for the interim final rule.
If you need guidance concerning compliance with the CTA, PilieroMazza attorneys are here to assist you. Please contact Meghan Leemon, Abby Baker, Cole Fox, or another member of the Firm’s Government Contracts or Business & Transactions practice groups.
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If you’re seeking practical insights to gain a competitive edge by understanding the government’s compliance requirements, tune into PilieroMazza’s podcasts: GovCon Live!, Clocking in with PilieroMazza, and Ex Rel. Radio.
[1] U.S. District Court for the Eastern District of Texas, Smith v. U.S. Department of the Treasury.
