202501.29
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The Ping-Pong Continues – But CTA Is Still on Hold

in 1) Business Law

The Corporate Transparency Act (CTA), designed to increase transparency and combat financial crime, continues to navigate a complex legal landscape. While the U.S. Supreme Court recently (January 23, 2025) reinstated the government’s ability to enforce the CTA, a separate nationwide injunction from another case challenging the law remains in effect, creating uncertainty for businesses.

Key Takeaways:

  • Conflicting Court Orders: The Supreme Court’s action was limited. A separate nationwide injunction issued by a different federal judge in Texas remains in place, effectively halting the enforcement of the CTA at this time.
  • No Mandatory Reporting Currently Required: Due to these conflicting court orders, companies are not currently required to report Beneficial Ownership Information (BOI) to the federal government as mandated by the CTA.
  • Voluntary Reporting Option: While not required, companies may still voluntarily submit BOI reports to the Financial Crimes Enforcement Network (FinCEN).

What This Means for Your Business:

This evolving legal situation creates uncertainty for businesses. While no immediate action is required regarding mandatory reporting, companies should stay informed about the ongoing legal developments surrounding the CTA.

Next Step:

  • Stay Informed: Schwartz Ettenger will continue to monitor the legal landscape and will provide any updates from FinCEN.

For further guidance on the CTA or any other corporate law matter, please contact the Schwartz Ettenger team to understand how these developments may specifically impact your company and to discuss potential compliance strategies.