Corporate Transparency Act Enforcement Resumes: What Businesses Need to Know

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The Corporate Transparency Act (CTA) continues its legal rollercoaster, with a significant recent development impacting businesses across the country. On February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted its nationwide preliminary injunction that had previously blocked the CTA’s enforcement in Smith, et al. v. U.S. Department of the Treasury, et al., Case No. 6:24-cv-00336. As a result, the CTA is once again in effect.

In response, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice on February 20, 2025, extending the deadline for most entities required to file Beneficial Ownership Information (BOI) reports. Businesses now have until March 21, 2025, to submit initial, updated, and corrected BOI reports.

What Businesses Need to Know About the New Deadlines

• Entities that previously had a reporting deadline later than March 21, 2025, can continue to rely on that later date.
• This includes businesses granted extensions due to disaster relief and entities created on or after February 20, 2025.
• FinCEN has indicated that it may issue further deadline modifications before March 21, 2025, to ease compliance burdens.

What’s Next for the CTA?

Although the CTA is back in force, uncertainty remains. Several legislative efforts and legal challenges could change its course:

• A House bill introduced on February 11, 2025, proposes extending the deadline for entities created before January 1, 2024, to file their initial BOI report until January 1, 2026.
• A Senate bill introduced on January 15, 2025, seeks to repeal the CTA entirely.
• Multiple lawsuits across the country continue to challenge the CTA’s constitutionality, leaving the law’s long-term future unclear.

Next Steps for Businesses

Given the evolving nature of the CTA, business owners must stay informed and ensure compliance with the latest reporting requirements. We encourage clients to monitor developments closely and check the FinCEN website for updates.

The Frazer Firm is here to help businesses navigate CTA compliance. If you have questions about how these changes impact your company, contact our team for guidance tailored to your specific needs.