CTA Reporting Requirements Paused – FinCEN Under Pressure

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January 24, 2025

In an alert posted this morning, FinCEN has announced that reporting companies are not currently required to file beneficial ownership reports even with the U.S. Supreme Court’s order yesterday.

Instead of issuing a new deadline for filing reports, FinCEN stated that despite the Supreme Court granting a stay (i.e., pause) of the nationwide block on enforcing the CTA, another nationwide order issued by a federal judge on January 7th remains in place (Smith v. U.S. Department of Treasury). This means that reporting companies are not required to submit beneficial ownership reports while the latest order halting CTA’s enforcement is in effect.

Given the ever-changing nature of the CTA’s enforcement (or lack thereof), reporting companies are encouraged to stay up to date. Ruder Ware’s CTA Team will continue to provide updates and answer questions on all things CTA as the legal battles progress.

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