In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.
On December 26, 2024, a federal court of appeals officially reinstated an injunction blocking the reporting deadline for Beneficial Ownership Information (BOI). This came just days after a panel lifted the injunction. This latest development means that the government cannot enforce the CTA and BOI reporting requirements and small businesses are under no obligation to file these reports while the court decides the case. Though small business owners should remain ready to file BOI reports, they do not have to submit reports. The injunction will remain in place while our lawsuit proceeds or until the court says otherwise.
Resources
- FinCEN’s BOI e-Filing System
- FinCEN Small Entity Compliance Guide
- Answers to Frequently Asked Questions
We encourage you to work directly with your attorney or legal counsel for further consultation or questions on the CTA and BOI Reporting.