Corporate Transparency Act Update: FinCEN to extend compliance deadlines and Treasury Department announces suspension of enforcement against U.S. citizens and domestic reporting companies

Once again, the Corporate Transparency Act (CTA) is on hold and will not be enforced pending further guidance from FinCEN. On February 20, we reported that FinCEN extended the compliance deadline to March 21 following the decision to lift the last remaining nationwide injunction. On February 27, FinCEN announced that it would not issue any penalties or enforcement actions against reporting companies for failure to comply with the CTA by the March 21 deadline. Instead, FinCEN plans to issue an “interim final rule” no later than March 21, 2025, which will contain extended reporting deadlines and further guidance.

The scope of the reporting obligations could also significantly change as the Treasury Department announced on March 2 that it intends to issue proposed rulemaking that would limit reporting obligations to only foreign reporting companies and alleviate U.S. citizens and domestic reporting companies from the regulatory burden of the CTA.  A copy of the Treasury Department’s press release can be found here.

Given the uncertainty around the CTA reporting requirements and enforcement, we recommend clients wait to file until FinCEN or the Treasury Department issues further guidance. We will provide an update once the additional guidance is issued by FinCEN. In the meantime, please do not hesitate to reach out to McDonald Hopkins with any questions or concerns.