On February 18, 2025, the U.S. District Court for the Eastern District of Texas, in Smith, et al. v. U.S. Department of the Treasury, et al., issued a stay on its January 7, 2025 order pending appeal. As a result, the beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”) are once again in effect, making compliance mandatory.
In response to this litigation development, the Financial Crimes Enforcement Network (“FinCEN”) has updated its website to notify reporting companies that the compliance deadline has been extended by thirty (30) calendar days, now falling on March 21, 2025.
It is imperative for reporting companies that have not yet filed their BOI reports to initiate the process of gathering the necessary information and submitting their reports as soon as possible. For further details on BOI reporting requirements, please refer to BBG’s article published on November 7, 2024, accessible here.
These deadlines are still subject to change as FinCEN also announced that during the 30-day period it will “assess its options to further modify deadlines.”
BBG continues to closely monitor updates to the CTA and remains fully equipped to assist and advise reporting companies and their beneficial owners on compliance matters.
Written by: Joshua A. Sycoff, Associate, Transactional
Zachary Rozycki, Law Clerk, Transactional
