UPDATE: Suspension of Enforcement of Fines and Penalties in Connection with the Corporate Transparency Act's latest Reporting Deadline of March 21, 2025

Following the establishing last month of its latest reporting deadline of March 21, 2025,the Financial Crimes Enforcement Network (“FinCEN”) has released a further statement, and the U.S. Treasury Department (of which FinCEN is a bureau) has issued a press release, stating it will not take any enforcement action to impose penalties or fines associated with the failure to file or update beneficial ownership information under the Corporate Transparency Act (the “CTA”) by the March 21, 2025 deadline. The Treasury Department will propose a new rule no later than the March deadline that will narrow the scope of the CTA’s reporting requirements to foreign reporting companies, and potentially non-U.S. citizen beneficial owners, only. The Treasury Department also stated in the press release it will not enforce any penalties or fines against U.S. citizens, domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect.

Subject to further updates from FinCEN and the Treasury Department, Reporting Companies that are U.S. entities with no foreign ownership may choose to suspend their preparation of beneficial owner reports at this time, given that no penalties or fines will be imposed for failure to file. Foreign entities, and domestic entities with foreign ownership, may wish to continue to prepare their reports and await the further guidance anticipated on or before March 21, 2025, before proceeding with filing.

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.