UPDATE: Federal Court Lifts Injunction on Enforcement of Corporate Transparency Act – New Mandatory Reporting Deadline of March 21, 2025

Following a series of reversals and reinstatements of injunctions over the last three months, the Corporate Transparency Act (the “CTA”) is back on again after a federal judge in Texas reversed the nationwide injunction he issued last month. As a result, the CTA’s reporting obligations are back in effect nationwide for all Reporting Companies. While further litigation is anticipated as parallel cases in Texas federal court and the Supreme Court (Smith v. United States Department of the Treasury, et. al. and Texas Top Cop Shop, Inc. v. McHenry) argue the constitutionality of the reporting requirements, and a bipartisan bill recently introduced in Congress proposes delaying reporting until the start of next year, the Financial Crimes Enforcement Network (“FinCEN”) have issued a statement establishing the new mandatory reporting deadline of March 21, 2025, which may be subject to further modification.

Given the continuing uncertainty of Reporting Companies’ obligations at this time, all entities subject to the CTA may wish to continue to prepare their FinCEN reporting materials in preparation for the March 21, 2025, deadline. All Reporting Companies should follow this matter closely as the future of the CTA remains uncertain and should be on the lookout for updates from the courts, FinCEN or subsequent reports from Wilk Auslander.

Reporting Companies can complete their BOI reports through the FinCEN portal here, or Wilk Auslander is happy to assist with filing. 

Please see our previous reporting on the CTA here and here.

We here at Wilk Auslander continually stay abreast of new developments and their applications in corporate law. If you would like to further discuss the CTA, please reach out to Stephen Albert at (212) 981-2320, salbert@wilkauslander.com, Jonathan Bender at (212) 981-2322, jbender@wilkauslander.com, Mark Clyman at (212) 981-2318, mclyman@wilkauslander.com, Jack Wilk at (212) 981-2333, jwilk@wilkauslander.com or Caitlyn Ford at (212) 981-2307, cford@wilkauslander.com.

At Wilk Auslander we advise businesses and entrepreneurs across a diverse spectrum of corporate and commercial dealings. Our clients range from startups to seasoned investors and small business to large multinational enterprises. We recognize the unique needs of each client, and craft innovative and cost-efficient strategies tailored to address their specific challenges and help them achieve their business objectives and corporate compliance while mitigating both immediate and long-term risks.