Temporary Pause on the CTA’s Beneficial Ownership Information Report Filing Requirements

By: Margaret Karakashian, Esq.

On December 3, 2024, the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc., et al. v. Garland et al. granted a nationwide injunction enjoining the Federal Government from enforcing the Corporate Transparency Act (“CTA”).

The CTA went into effect on January 1, 2024 and requires a wide range of entities formed in the U.S. or registered to transact business in the U.S. to file a beneficial ownership information report (“BOIR”) with the U.S. Department of Treasury’s Financial Crimes Enforcement Network. The CTA was enacted by Congress as part of the Anti-Money Laundering Act of 2020 as an attempt to better enable critical national security, intelligence and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity.

As a result of this preliminary injunction issued by the U.S. District Court, reporting companies can hold off on filing a BOIR at this time. However, this is not a final decision and given the looming deadline for many reporting companies, we advise that such companies continue gathering the necessary information in preparation of filing their BOIR. Please see our prior alert, Corporate Transparency Act: What You Need to Know, for more information regarding BOIR filing deadlines; if you were impacted by Hurricane Milton, please see the article, Beneficial Ownership Information Report Filing Deadline Extended Six-Months for Companies Impacted by Hurricane Milton, for more information regarding your extended BOIR filing deadline.  

We are monitoring developments in this regard and will continue to keep you informed through our alerts. If you have any questions, you may contact us by email at info@henlaw.com or by phone at 239-344-1100.