This is a further update on the alert we issued on February 21, 2025 regarding the Corporate Transparency Act (“CTA”) and its beneficial ownership information (“BOI”) reporting requirements affecting limited liability companies and certain other entities. The BOI reporting requirements under the CTA previously reinstated following the ruling in Smith, et al. v. U.S. Department of the Treasury, et al. (Case No. 6:24-cv-00336) have now been halted by the U.S. Department of the Treasury.
On March 2, 2025, the Treasury Department announced that it will not enforce any penalties or fines associated with the BOI reporting requirements under the CTA against U.S. citizens or domestic reporting companies or their beneficial owners. Instead, the Treasury Department will issue a proposed rulemaking that will narrow the scope of the BOI reporting requirements to apply to foreign reporting companies only.
This Treasury Department announcement follows the February 27, 2025 announcement by its Financial Crimes Enforcement Network (FinCEN) that it would not take any enforcement actions against any companies based on any failure to file or update BOI reports by the current March 21, 2025 reporting deadline.
If you have questions about the CTA, please contact one of our partners: Matthew S. Quinn, at (212) 447-5510 or mquinn@QMlegal.com, Christopher P. McCabe, at (212) 447-5520 or cmccabe@QMlegal.com, Simon Block, at (212) 447-5530 or sblock@QMlegal.com, Jonathan Krukas, at (212) 447-5560 or jkrukas@QMlegal.com, or Eric Thorsen, at (212) 447-5570 or ethorsen@QMlegal.com.
PREVIOUS UPDATE: Corporate Transparency Act’s Beneficial Ownership Information Reporting Requirements Back In Effect
FIRST UPDATE: Preliminary Injunction Enjoining Enforcement of the Corporate Transparency Act Reinstated
ORIGINAL ARTICLE: Corporate Transparency Act (“CTA”) and its beneficial ownership information (“BOI”) reporting requirements
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