FinCen suspends Corporate Transparency Act enforcement

On February 27, 2025, FinCEN announced that no fines, penalties or any other enforcement actions will be taken based on reporting companies’ failure to file BOI reports by the current deadlines (previously extended to March 21, 2025) until a forthcoming interim final rule becomes effective.

However, on March 2, 2025, the Treasury Department went further and indicated it is unlikely to impose reporting obligations and associated penalties or fines on US citizens, domestic reporting companies or their beneficial owners even after the forthcoming interim final rule changes take effect. Instead, when the Treasury Department issues a new interim final rule, it appears reporting obligations under the CTA will only apply to foreign reporting companies, which is a concept that remains to be defined.

For more information on the zig-zagging of the previous court orders, see our prior analysis:

• “Corporate Transparency Act enforcement is back in effect”
• “US government still pausing the Corporate Transparency Act enforcement, despite US Supreme Court win”
• “Corporate Transparency Act reporting requirements on pause...again”
• “A Texas-sized injunction for the Corporate Transparency Act”

For more information on the reporting requirements and common pitfalls of the CTA, see:

• “The Corporate Transparency Act is here—are you ready?”
• “New year, new reporting requirements”