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Keeping owners, managers, and stakeholders up to date on issues affecting their businesses.

BOI Enforcement Action Halted Again

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies based on failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act (CTA) by the current deadlines.

The CTA Returns

Enforcement of the Corporate Transparency Act (the “CTA”) will resume--with an extended deadline--after a federal court in Texas granted the U.S. government’s motion to pause a nationwide injunction.

Another CTA Turn: One Beneficial Ownership Information Filing Stay Lifted, But Another Remains

On January 23, 2025, the U.S. Supreme Court granted the federal government’s request to stay a nationwide injunction against enforcing the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements. The injunction originally was issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland).

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