LEGAL UPDATE: December 27, 2024
Another update on the fast-moving CTA litigation: as of about 7:30 p.m. last night (December 26, 2024), CTA enforcement is once again ON HOLD. The government’s appeal was assigned to a new Fifth Circuit panel, and that panel vacated the prior panel’s stay pending appeal. As a result, the CTA’s BOI reporting requirements, including any January 2025 reporting deadlines for preexisting companies, are suspended until further notice.
TAKEAWAY: there is currently no need to submit BOI reports/filings to FinCEN.
Obviously, CTA compliance continues to be a fluid situation as ongoing litigation works its way through the appeals process, and FMJ will continue to monitor. Please do not hesitate to reach out to Pat Shriver, Brad Hutter, or any of the other members of our Corporate Practice Group with questions about CTA compliance.
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