The pre-Christmas lifting of a nationwide preliminary injunction enjoining the federal government from enforcing the Corporate Transparency Act (“CTA”) has itself recently been reversed.  Accordingly, the nationwide injunction against the CTA has been reinstated and companies are again currently not required to make any filings under the CTA.   

 The State of Play and Next Steps

 Among the current legal maneuvers in the case, the government has filed applications with the Supreme Court to lift or narrow the current preliminary injunction. In the meantime, the current injunction will remain in place while the case proceeds through the courts. Companies that, but for the injunction, would otherwise be required to make filings under the CTA, are currently not require to do so, but may do so voluntarily.  We recommend continuing to collect information and preparing to submit the applicable reports should those filings again become necessary.  Casner & Edwards will continue to monitor developments and provide updates. 

 Background Information

The CTA is a new federal law that took effect on January 1, 2024.  It was enacted to combat money laundering, and under the CTA, all companies that are “reporting companies” must file certain beneficial ownership reports with the Department of Treasury’s Financial Crimes Enforcement Network.  Information on the CTA and its requirements and exemptions can be found in our previous client alerts of January 31, 2024 and October 15, 2024.  Additional information on the nationwide injunction can be found in our previous client alerts of December 10, 2024 and December 24, 2024.

Questions                                               

If you have any questions, please contact Casner & Edwards attorneys Peter Dunn, Michael Zullas, Steven Ayr, or Drew Douglas-Steele.