The CTA Returns

Lucas P. Sczygelski | 02.19.25

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

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced on Wednesday that in response to this ruling, it is extending the CTA filing deadline for most reporting companies to March 21, 2025. In that same announcement, FinCEN indicated that it will seek to revise certain CTA reporting rules to ​“reduce burden for lower-risk entities including many U.S. small businesses.” FinCEN did not provide details on the nature of that potential relief. 

For now, companies with a reporting obligation under the CTA that have not previously filed should prepare to file reports before the new March 21, 2025, deadline. Companies that have previously filed but have had a change in the information that needs to be reported should file updates promptly.

As we’ve written about previously, the CTA was enacted by Congress in 2021 to prevent money laundering behind the mask of shell company structures. Prior to a series of judicial challenges, it was set to impose various reporting requirements on most entities registered to conduct business in the United States, effective January 1, 2025. A number of challenges to the legality of the CTA remain pending, including an appeal to the U.S. Court of Appeals for the Fifth Circuit for which oral arguments are scheduled for April 1, 2025. 

If you have questions about what this latest CTA ruling means for you and your entities, please contact the primary Boardman Clark attorney with whom you work or call us at (608) 257 9521 to speak with one of our business attorneys.

• Corporate Transparency Act (CTA)