Following our previous update regarding the Corporate Transparency Act (“CTA”) (at which time FinCEN had reinstated filing deadlines for beneficial ownership information (“BOI”) as of March 21, 2025), on February 27, FinCEN announced that all reporting and enforcement of the CTA would be suspended “until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed”.
Subsequent thereto, on March 2, 2025, the U.S. Treasury Department stated that it will not only not enforce any penalties or fines associated with the BOI reporting rule pursuant to the CTA under existing deadlines, but it will not enforce penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners, even under forthcoming rule changes. The Treasury Department intends to issue a “proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only”. The effect of these proposed changes to the enforcement of the CTA, and to the CTA itself, remains to be seen.
We will continue to monitor these rule changes and provide updates as they evolve.
