Regulatory Whiplash. Corporate Transparency Act (CTA) Reporting Is Back On. Again.

If you’ve been following the rollercoaster of Corporate Transparency Act (CTA) enforcement, you know businesses have been caught in a game of regulatory ping-pong. First, a federal court in Texas ruled that FinCEN couldn’t enforce the CTA against a particular plaintiff, leading to speculation about broader implications. Then, just weeks later, another decision allowed enforcement to resume, leaving businesses wondering whether they needed to report their beneficial ownership information. Now, we have yet another update: as of February 18, 2025, the CTA is back in effect nationwide—at least for now.

Here’s what you need to know:

• The injunction blocking the CTA was lifted, meaning FinCEN can once again enforce the reporting requirements.
• New deadline: Most companies that would have been required to report during the injunction period now have until March 21, 2025, to comply.
• Possible extensions: FinCEN is considering additional deadline relief for lower-risk entities.
• Businesses formed in late December 2024 may get extra time due to the standard 90-day filing window.
• If your deadline was already beyond March 21, 2025, it remains unchanged.

For businesses that have been in limbo, the best course of action is to assume compliance is required and prepare to file. While further legal challenges are possible, the CTA is enforceable once again, and missing deadlines could lead to penalties. If you need help navigating these shifting requirements, now is the time to act.

Stay Updated
To learn more or voluntarily submit your BOI, visit the FinCEN website by clicking here or on YouTube here: Financial Crimes Enforcement Network (FinCEN) – YouTube

Consult with your New York business lawyer or New Jersey business lawyer so you’re prepared for any updates to compliance requirements.

*****************************

*This blog post from Russo Law LLC is for informational purposes only. It is not an offer for Russo Law LLC to represent you and does not provide, nor does it intend to provide, legal advice. You should not act, or refrain from acting, based upon any information on this website. Neither the presentation of such information nor your receipt of the same creates an attorney-client relationship.

This blog is lawyer/attorney advertising. Although this blog post intends to provide accurate and helpful information, it makes no representations, claims, promises, guarantees, or warranties, express or implied, including the warranties of merchantability and fitness for a particular purpose. Prior results do not guarantee a similar outcome.

Finally, Russo Law LLC does not assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed on this website, nor represents that its use would not infringe upon privately owned rights.