Despite what experts had thought, yet another update on the Corporate Transparency Act (CTA) was released yesterday. Last week, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced an extended filing deadline of March 21, 2025 as an immediate response to the decision from the U.S. District Court for the Eastern District of Texas lifting the injunction staying CTA enforcement.

On February 27, 2025, FinCEN announced that it intends to issue an interim final rule some time before the March deadline with new extended beneficial ownership information (BOI) reporting deadlines. No fines or penalties will be imposed and no enforcement actions will be taken until the interim final rule becomes effective and the new relevant due dates in the rule have passed.

In the meantime, if your entity has yet to file or update a BOI report, there is no harm in waiting it out until the new rule has passed. However, there would also be no harm to proceed with filing or updating a report at this time if you prefer to just get it done. If you decide to wait it out, we recommend being prepared with all of the information you will need to file as there is no way of knowing how close the new deadlines will be to the date when they are announced.

This article was written by Rachel L. Partain, a 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.