Corporate Transparency Act Update – Reporting Requirements Are Back

Update February 28, 2025: No Fines or Penalties Pending Extension of Deadlines

The Financial Crimes Enforcement Network (FinCEN) announced it will not issue any fines or penalties for failure to file or update Beneficial Ownership Information (BOI) reports by the current deadlines.

By March 21, 2025, FinCEN intends to issue an interim final rule that will extend the Corporate Transparency Act’s BOI reporting deadlines. There will be no fines, penalties, or enforcement actions until the forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.

As always, our attorneys and Business Services professionals are available to help. Please contact our team if you have questions or would like assistance with your company’s Beneficial Ownership Information reporting.

Original Article

On February 18, 2025, a U.S. District Court for the Eastern District of Texas stayed the preliminary injunction which halted enforcement of the Corporate Transparency Act’s (CTA) reporting requirement.

This action means the CTA’s reporting requirements are once again in effect and mandatory.

FinCEN issued guidance about updated reporting deadlines. Most companies are required to file a report by March 21, 2025. Going forward, newly formed companies will have 30 days from the date of formation to file their initial report.

This is likely not the last word on the CTA and its reporting requirements. Litigation is ongoing and Congress is considering a bill to extend the reporting deadline. In its most recent guidance, FinCEN held open the possibility of further changes to the filing deadlines.

In light of this most recent development, companies that have not filed their BOI report should prepare to meet the current deadline.

Woods Rogers Corporate & Business Transactions attorneys and Business Services professionals will monitor the situation and provide updates as needed. Please contact the authors of this article, your Woods Rogers attorney, or anyone on our team if you would like assistance with preparing and filing your company’s Beneficial Ownership Information report.