A Texas federal court has issued a nationwide injunction temporarily blocking the enforcement of the Corporate Transparency Act (CTA), originally set to take effect on January 1, 2025.

The CTA requires corporations, LLCs and other legal entities to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). However, the Texas court’s ruling on December 3, 2024, prohibits the U.S. Department of Treasury from enforcing these requirements.

The CTA’s BOI reporting obligations aim to combat financial crimes such as terrorist financing, drug trafficking, and money laundering by closing corporate loopholes exploited by bad actors. Despite these objectives, the court’s injunction cited concerns that the CTA imposes excessive burdens on small organizations and may infringe upon state sovereignty.

In response, the U.S. Department of Justice filed a Notice of Appeal on December 5, 2024. Pending the outcome of that appeal, the Treasury Department has updated its online guidance, stating that BOI submissions are now voluntary and legal entities “are not subject to liability” for failing to file BOI reports with FinCEN while the injunction remains in effect.

For Legal entities required to report, this injunction provides a temporary and optional reprieve from compliance efforts until the legal challenges are resolved. They will need to decide whether to voluntarily comply or wait for the resolution of the appeal. In either case, they should remain vigilant, as future rulings may reinstate CTA requirements or modify compliance obligations.

For a more detailed discussion with links to the Department of Treasury websites referenced above, see our article, Court Temporarily Blocks Corporate Transparency Act.

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