Key takeaways
- U.S. Department of the Treasury announces CTA will not be enforced against U.S. citizens or domestic reporting companies or their beneficial owners pending further rule-making
- Department states new proposed rule will narrow scope of reporting obligations to foreign reporting companies only
On February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an extended deadline of March 21, 2025 for reporting companies to file initial, updated or corrected BOI reports. FinCEN also committed to assessing further relief for “lower-risk entities” via future rule-making. After weeks of stalled enforcement of the Corporate Transparency Act (CTA) due to multiple ongoing lawsuits challenging the law, this announcement provided some clarity for reporting companies about their filing obligations and deadlines. However, promptly after this announcement, the U.S. Department of the Treasury issued additional pronouncements that leave reporting companies and their beneficial owners uncertain about what comes next.
On February 27, 2025, FinCEN announced that it would not issue any fines or penalties or take any enforcement action against reporting companies for their failure to file BOI reports by the applicable deadline and that all enforcement is on hold pending the effective date of a forthcoming rule that FinCEN is working on to reduce the burden on small businesses.