On December 3, 2024, the U.S. District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementation of regulations nationwide.[1] Shortly following the ruling, the Department of Justice filed a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit.[2]

The CTA, effective on January 1, 2024, requires specific business entities (reporting companies) to file beneficial ownership information reports with the U.S. Financial Crimes Enforcement Network (FinCEN). Under the CTA, reporting companies existing prior to January 1, 2024, are required to submit initial beneficial ownership information reports to FinCEN by January 1, 2025, and those formed or registered after January 1, 2024, must file within 90 days of formation or registration (and 30 days after formation in 2025 and beyond). For more background information on the CTA, please read our series: The Corporate Transparency Act (Parts 1-4).