Off Again, On Again: The CTA Revived

Key Takeaway: Following a court decision on February 18, 2025, the Corporate Transparency Act’s (CTA) beneficial ownership reporting requirements are once again in effect. Most companies will have until Friday, March 21, 2025, to file any necessary reports.

On February 18, 2025, the U.S. District Court for the Eastern District of Texas in Smith, et al. vs. U.S. Department of Treasury et al. granted the federal government’s motion to stay the nationwide injunction blocking CTA enforcement until the government’s appeal is decided. The CTA’s beneficial ownership reporting requirements are now back in effect.

Per a notice issued February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) has generally extended the reporting deadline for most companies to March 21, 2025. Any entities previously given a reporting deadline later than March 21, 2025, for example, in response to a disaster relief exemption, may continue to abide by that later deadline.

In the notice, FinCEN indicated that it will continue to monitor developments and may extend deadlines further, while prioritizing reporting for companies posing high national security risks. Any update on an extended deadline will be provided before March 21. FinCEN also revealed plans to initiate a process to revise CTA reporting requirements to reduce the burden on low-risk entities, including many small businesses.

For more information, please refer to MoFo’s CTA Resource Center.