In yet another turn of events, the U.S. Department of Treasury announced over the weekend that it will not be enforcing any penalties or fines associated with the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting rule, even after any forthcoming rule changes that we discussed in our alert on Friday, February 28 take effect. According to its press release, the Treasury Department will be issuing proposed rulemaking that will narrow the scope of the CTA to foreign reporting companies only.

While the status of current litigation against the CTA, and any future challenges, remains uncertain, the Treasury Department has made it clear that, for now, enforcement actions against U.S. citizens and domestic reporting companies are dead in the water. If your entity is domestic and has yet to file or update a BOI report, we recommend sitting tight for now given the Treasury Department’s announcement of discontinuation of enforcement.

This article was written by Rachel L Partain, partner in 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.