In the latest news, on February 17, 2025, the U.S. District Court for the Eastern District of Texas lifted the previously issued preliminary injunction on the enforcement of the Corporate Transparency Act (CTA). Given this decision, beneficial ownership information (BOI) reporting requirements are once again back in effect and mandatory. As a result, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) is providing additional time for companies to comply and has just issued a statement with the following new filing deadlines:
- For most reporting companies, the deadline for filing an initial, updated, and/or corrected BOI report is now extended to March 21, 2025.
- For new companies formed on or after February 18, 2025, the deadline for filing an initial BOI report is within 30 days from the date of creation or registration.
- For reporting companies that were previously given a reporting deadline later than March 21, 2025, such as reporting companies that qualified for certain disaster relief extensions, the deadline to file their initial BOI report is that later deadline given.
This is a fast-changing environment and it is possible these deadlines may change again, possibly by FinCEN or an act of Congress. As more developments in this space unfold, we will continue to monitor the CTA reporting deadlines and provide updates regarding any further changes to the CTA’s reporting requirements. However, in light of this most recent decision, we recommend that non-exempt companies that have not yet filed a BOI report take prompt action to do so within the deadlines stated in this latest notice from FinCEN.
This article was written by Joseph V. Cuomo, Co-Chair of the firm’s Corporate and Mergers & Acquisitions practice group and Caroline G. Frisoni, an associate in the group. Should you have questions on CTA compliance, please reach out to our Corporate Department or call 516-248-1700.