LATEST UPDATE on the Corporate Transparency Act and New Deadline for Filing BOIR

On February 13, 2025, we published an article titled “Updates Regarding the Corporate Transparency Act Hold: Key Implications for Businesses." This article will serve as another update to the ongoing Corporate Transparency Act developments. As of February 17, 2025, a federal judge in the Eastern District of Texas lifted the injunction it had ordered on January 7, 2025, in Smith v. U.S. Department of the Treasury, 6:24-cv-00336 (E.D. Tex.), allowing the federal government to once again enforce the Corporate Transparency Act and its Beneficial Ownership Information Report requirements.

Note that FinCEN has instituted a new March 21, 2025, deadline for all Reporting Companies that have not yet filed their initial FinCEN BOIRs, although FinCEN has stated that it will assess its options to further modify deadlines while prioritizing reporting for those entities that pose the most significant national security risks. Further, FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many US small businesses. For further inquiries or questions, please contact Attorney Frank J. Portera at fportera@lavellelaw.com or (847) 705-7555.