February 21, 2025

Summary:

Compliance Deadline Extended: United States businesses now have until March 21, 2025, to submit their beneficial ownership information (BOI) reports to the Financial Crimes Enforcement Network (FinCEN).
Next Legal Steps: The U.S. Fifth Circuit Court of Appeals will hear oral arguments on March 25, 2025, which could further impact CTA enforcement.

Recent Developments in CTA Enforcement

On January 23, 2025, the U.S. Supreme Court issued a key ruling that allowed the full enforcement of the CTA by lifting an injunction that had temporarily blocked the law's implementation. This was a significant step in the ongoing legal battles surrounding the law. However, while the Supreme Court ruling set the stage for compliance, the U.S. District Court for the Eastern District of Texas recently lifted the last major injunction, temporarily clearing the path for the Treasury Department to enforce the CTA.

New Compliance Deadline: March 21, 2025

In light of recent legal developments, the U.S. Treasury Department has extended the deadline for most businesses to submit their beneficial ownership information (BOI) reports to March 21, 2025. This new deadline applies to most businesses, but there are important exceptions to note.

Businesses that received an extension due to specific circumstances (e.g., qualifying for disaster relief) may file their BOI reports by any later deadline they received. For example, a business that qualified for disaster relief with a deadline in April 2025 may adhere to that April 2025 deadline rather than the March 21, 2025 deadline. It is crucial for businesses to review their eligibility and confirm their correct reporting deadline to ensure full compliance and avoid potential penalties.

What's Next in the Legal Process?

The case is far from over. While most businesses now have until March 21, 2025, to comply with the CTA, there are efforts underway to extend the reporting deadline even further. On February 10, 2025, the U.S. House of Representatives passed a bill to push the CTA reporting deadline to January 1, 2026. However, the Senate has yet to act on this bill, and its outcome remains uncertain.

The U.S. Fifth Circuit Court of Appeals is to hear oral arguments on March 25, 2025, and their ruling could set precedents affecting future enforcement of the CTA. The case remains in legal flux, but prudence suggests that businesses not to wait for a final decision and instead proceed with compliance to avoid penalties.

Why Compliance is Essential for Your Business

Even as the legal landscape continues to evolve, businesses should prioritize compliance with the CTA. The March 21, 2025 deadline is final unless further legislative action alters that deadline, and non-compliance could result in hefty fines. If your business has already submitted its beneficial ownership information, you are ahead of the game. But if you have not, now is the time to ensure you are in full compliance.

For guidance on submitting your report visit our Guide to Beneficial Ownership Information (BOI) Reporting. Keeping your business compliant with these new transparency requirements will help safeguard against penalties and ensure you stay in good standing with federal regulations.

Stay tuned to our news page for further updates on the CTA and other legal developments that could impact your business.