Treasury Announces Suspension of Enforcement of Corporate Transparency Act

The Treasury Department announced March 11, 2025, that it will not enforce penalties or fines associated with the beneficial ownership information reporting rule under existing regulatory deadlines pursuant to the Corporate Transparency Act (CTA). The Treasury Department also indicates it will be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only.

A final rule issued by the Department of Treasury and Financial Crimes Enforcement Network (FinCEN) imposed beneficial ownership information (BOI) reporting requirements affecting IRA-owned businesses. Entities in existence before January 1, 2024, were required to file an initial report before January 1, 2025.  Two U.S. District Courts have held that the CTA is likely unconstitutional, and in both cases, the Court granted a preliminary injunction to temporarily block the enforcement of the CTA. On January 23, 2025, the U.S. Supreme Court stayed the lower courts’ decision that the CTA is unconstitutional. On January 23, 2025, the U.S. Supreme Court stayed the lower court’s decision that the Corporate Transparency Act (the “Act”) is unconstitutional. The stay would allow the federal government to enforce the Act. As the deadline passed while the lower court orders were in effect, it was unclear when such filings would have been required.