On December 26, 2024, a merits panel for the US Court of Appeals for the Fifth Circuit (Fifth Circuit) vacated the previously reported December 23, 2024 stay, giving new life to the nationwide preliminary injunction of the Corporate Transparency Act (CTA) and its implementing regulations issued by the US District Court for the Eastern District of Texas earlier this month. As a result, enforcement of beneficial ownership information (BOI) reporting requirements is once again paused, pending further court action. While we await further court action, reporting companies are not currently required to file beneficial ownership information with the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and are not subject to liability if they fail to do so.
