2025-03-12
After much back and forth in the courts, FinCEN set a deadline of March 21, 2025, for companies to submit their beneficial ownership information reports. Then, on March 2 , 2025, the Treasury Department announced that they will be issuing a new rule, and will not enforce the existing compliance deadlines or penalties or fines associated with the CTA against U.S. citizens and domestic reporting companies after an impending rule change is placed into effect.
According to the Treasury Department, the CTA reporting rules are set to be narrowed to reduce the number of companies affected by the CTA. If the Treasury Department is successful in making this rule change, the CTA would be limited to foreign reporting companies.
The filing of this information with FinCEN is not currently required, but the CTA enforcement efforts indicate that this could change. Businesses may still choose to voluntarily comply with the CTA’s mandates, but for the time being, there is no penalty for failing to do so.
Given the uncertainty that has surrounded the CTA, it is recommended that businesses maintain their beneficial ownership information on file in case it is needed in the future, and remain ready to comply if that FinCEN changes course and decides to reinstate enforcement.