DOJ appeals CTA Injunction, FinCEN suspends filing requirement
The CTA regulations set January 1, 2025 as the reporting deadline for any covered companies created or registered prior to January 1, 2024.0 The CTA regulations have set a January 1, 2025 reporting deadline for all covered companies that were created or registered before January 1, 2024. FinCEN’s website has posted an alert that offers the following guidance. Reporting companies can continue to submit beneficial ownership reports voluntarily. This alert confirms that filings are not required until the injunction is lifted or the Fifth Circuit grants an interim relief. Firms may want to wait for further clarification before submitting any reports. We still believe that it is prudent for firms subject to the deadline of January 1, 2025 to continue preparing their CTA filings. If the DOJ receives interim or expedited resolution in the coming weeks, and the injunction has been lifted, preparing for the CTA filings now could help avoid having to make the filings at short notice. Please contact your usual contacts at the firm if you have any questions about this memorandum.
