In a blog posted earlier this year, Anderson Leavitt LLC informed its readers that a federal court ruled that the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCen”) did not have jurisdiction to enforce the Corporate Transparency Act’s (“CTA”) beneficial ownership information (“BOI”)  reporting obligations.  We were careful to advise that the court’s ruling only extended to the plaintiff in that specific case and while we stated that compliance with the CTA would likely be extended, we indicated the smart approach would be to begin compliance as the fines and penalties for noncompliance would greatly outweigh the small administrative burden of actual compliance.

Nationwide Injunction Issued

Yesterday, December 3, 2024, the Texas court issued a nationwide injunction enjoining FinCen from enforcing BOI reporting requirements under the CTA.  As a result, business entities do not have to report BOI to FinCen.  Most likely the Department of Justice will appeal this decision but for now, compliance is not required.  As of this posting, FinCen has not commented on this recent decision.

If you have any questions regarding compliance, or any other aspect of your business, please feel free to contact Doug Leavitt at Anderson Leavitt.

This entry is presented for informational purposes only and is not intended to constitute legal advice.