There is yet another update with respect to the Corporate Transparency Act (the “CTA”). Less than two weeks after the U.S. Treasury Financial Crimes Enforcement Network (“FinCEN”) set a new deadline for CTA compliance, both FinCEN and the U.S. Department of Treasury issued separate press releases announcing their intent to not enforce the CTA until new rules are finalized.

Specifically:

1. On February 27, 2025, FinCEN announced that it would not issue fines or penalties or take any other enforcement action against any company based on the failure to file the required beneficial ownership information (BOI) reports before an interim final rule becomes effective. Click here for full announcement. FinCEN also announced its intent to extend reporting deadlines.
2. On March 2, 2025, the Treasury Department went a step further and announced that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners even after the forthcoming rule change takes effect. Click here for the full announcement. Consistent with this, the Treasury Department indicated its intent to narrow the scope of CTA regulations to apply to foreign reporting companies only. The term “Foreign Reporting Company” is generally defined in the CTA as an entity not formed in the U.S., but that is registered to do business in the U.S.

Continued monitoring and analysis to evaluate the effects of these announcements and upcoming regulatory changes will be necessary.

The attorneys are Stites & Harbison are available to help.