Mergers & Acquisitions

Fifth Circuit Reinstates CTA injunction pending oral arguments in March; FinCEN deadline of January 13 on hold

The Fifth Circuit’s merits panel will now be considering the DOJ’s appeal. As a result, the nationwide preliminary injunction originally granted by the district court is once again in effect. The Fifth Circuit has scheduled oral arguments in late March 2025. As a result of this decision, the district court’s nationwide preliminary injunction is now in effect. FinCEN has recently extended various filing deadlines. As discussed in our Client Alert of December 24, the deadline set for reporting companies that were created or registered before 2024 is January 13, 2025. We will continue to monitor this situation. If you have any questions about this memorandum please contact your regular contact at the firm.

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