On December 3, 2024, the U.S. District Court issued a nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This includes the Beneficial Ownership Information (BOI) Reporting.
The court ruled in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al. that neither the CTA nor the rules adopted by the Financial Crimes Enforcement Network (FinCEN) may be enforced.
Below are the immediate recommended actions for both businesses that have and have not yet filed their BOI reporting with FinCEN.
Businesses that have filed with FinCEN:
- No immediate action required
- Stay updated on future litigation and policy changes
Businesses that have not filed with FinCEN:
- Delay filing – you are not currently required to comply with the CTA
- Be prepared – the injunction may be overturned and businesses would need to act quickly to meet reporting deadlines. Having established compliance processes in place and consulting with legal advisors beforehand will help mitigate risks
We encourage you to work directly with your attorney or legal counsel for further consultation or questions on the CTA and BOI Reporting.