Update on Corporate Transparency Act and FinCEN’s Pause on Enforcement Actions

 Posted on March 03, 2025 in Business

The Corporate Transparency Act ("CTA") and its Beneficial Ownership Information ("BOI") reporting deadlines are back in effect after months of judicial whiplash. As detailed in our prior blogs, the enforceability of the CTA has recently been challenged in multiple forums and lawsuits. Ultimately, the Government has prevailed (for now) and the BOI reporting deadlines have been reinstated with many companies facing a March 21, 2025, deadline.   

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a stunning release that it will not impose any fines or penalties against companies for failure to file or update their BOI reports by the March 21st deadline. FinCEN will not take any enforcement actions until it establishes a new reporting deadline. FinCEN intends to issue this new deadline no later than March 21, 2025.

FinCEN appears to acknowledge the recent confusion and frustrations surrounding the CTA’s status as it claims to recognize "the need to provide new guidance and clarity as quickly as possible, while ensuring that BOI that is highly useful to important national security, intelligence, and law enforcement activities is reported." 

We encourage all reporting companies to monitor the forthcoming reporting deadlines and new developments through FinCEN's Website. Please contact the attorneys at Mallery s.c. with any questions or concerns regarding CTA compliance.