Corporate Transparency Act Enforcement Resumes: Key Deadlines & Compliance Risks

Corporate Transparency Act Enforcement Resumes: Key Deadlines & Compliance Risks

An article by the law firm Burr&Forman highlights the latest on the Corporate Transparency Act enforcement.

On February 18, 2025, the last nationwide injunction blocking enforcement of the Corporate Transparency Act (CTA) was lifted in Smith v. US Department of the Treasury (E.D. Tex.). This followed a Supreme Court order in McHenry v. Texas Top Cop Shop, Inc. on January 23, 2025, which prompted District Judge Jeremy Kernodle to stay his earlier injunction. As a result, the Financial Crimes Enforcement Network (FinCEN) has resumed enforcing the CTA’s beneficial ownership information (BOI) reporting requirements.

Updated Deadlines

With enforcement reinstated, the article highlights the following deadlines for CTA compliance:

• March 21, 2025: Deadline for most companies to submit initial, updated, or corrected BOI reports.
• Previously Extended Deadlines: Reporting companies with a later deadline must adhere to their original filing extension.
• New Entities: Newly formed companies must file BOI reports within 30 days of formation.

FinCEN is reviewing potential modifications to reporting deadlines, but companies should assume the March 21 deadline remains firm unless further guidance is issued.

Key Takeaways for Risk & Compliance Professionals

• Immediate Compliance Required: Companies that delayed BOI reporting due to the injunction must now act swiftly to meet the March 21 deadline.
• Monitor Regulatory Updates: FinCEN may announce further changes; legal and compliance teams should stay informed.
• Prepare Documentation Now: Organizations should gather and verify beneficial ownership data to ensure timely filing.
• Assess Risk Exposure: Companies should evaluate whether non-compliance could expose them to enforcement actions or penalties.

Given the evolving regulatory landscape, proactive compliance is essential to mitigate risk.