Corporate Transparency Act: Fifth Circuit Reinstates Filing Deadline: Act Now to Comply
Corporate Transparency Act: Fifth Circuit Reinstates Filing Deadline: Act Now to Comply
In a significant development, the U.S. Court of Appeals for the Fifth Circuit has lifted the nationwide preliminary injunction that had temporarily halted enforcement of the Corporate Transparency Act (CTA). With this decision on December 23, 2024, the original January 1, 2025 deadline for filing Beneficial Ownership Information (BOI) reports is back in effect.
The CTA, administered by the Financial Crimes Enforcement Network (FinCEN), mandates that certain entities disclose key information about their beneficial owners. This measure aims to combat money laundering, terrorism financing, and other illicit activities by increasing transparency in corporate ownership structures.
What This Means for Affected Entities
With the reinstated deadline rapidly approaching, entities subject to the CTA must prioritize compliance to avoid steep penalties for non-compliance. Although the Fifth Circuit’s decision has reestablished the timeline, FinCEN has yet to issue any updates or extensions regarding the BOI filing requirements. As of now, the January 1, 2025 deadline remains firm.
Entities covered under the CTA should immediately:
1. Identify Beneficial Owners: Ensure all individuals meeting the criteria for beneficial ownership are properly documented.
2. Gather Required Information: Collect essential details such as names, addresses, dates of birth, and other identification information as specified by FinCEN.
3. Submit Reports Promptly: Utilize the official FinCEN reporting mechanisms to file BOI reports well before the deadline.
Stay Informed
The Fifth Circuit’s decision underscores the importance of adhering to regulatory requirements and staying informed about changes that may impact compliance obligations. Given the current lack of updated guidance from FinCEN, affected entities are encouraged to act swiftly and proactively.
For more information and to review the Fifth Circuit’s order, click here. If you would like to read our previous articles on the subject, click here. If you have questions about your organization’s obligations under the CTA or need assistance with compliance, reach out to your legal or financial advisors without delay.
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