Corporate Transparency Act Enforcement Resumes Following Court Decision

On February 18, 2025, Judge Jeremy Kernodle of the U.S. District Court for the Eastern District of Texas issued an order stating the nationwide injunction blocking the Corporate Transparency Act (CTA). This is consistent with the Texas Top Cop Shop precedent.

FinCEN (Financial Crimes Enforcement Network) posted a notice that same day saying that the March 24, 2024, deadline for most companies to file their Beneficial Ownership Information (BOI) reports is now March 25, 2025. That deadline is for companies formed or registered between January 1, 2024, and February 17, 2025.

For companies created or registered after February 18, 2025, FinCEN says the BOI must be filed within 30 days of creation or registration. These deadlines reflect FinCEN’s current interpretation after the court ruling.

FinCEN also said it will review over the next 30 days and may modify some deadlines based on risk, prioritizing entities that pose a significant national security risk. In the same notice, FinCEN plans to start the rulemaking process later this year to ease the reporting burden for lower-risk entities, especially small businesses.

This ruling and FinCEN’s notice are a big deal in the ongoing regulatory process for the Corporate Transparency Act. The regulation was enacted as part of the Anti-Money Laundering Act of 2020 and requires companies to disclose information about their beneficial owners to FinCEN to prevent the use of shell companies for illegal activities like money laundering, tax evasion, and terrorist financing.

Legal experts don’t think the government will appeal Judge Kernodle’s February 18 ruling so these deadlines should stand unless something changes. But the Texas Top Cop Shop case itself is still alive, with oral arguments set for March 25, 2025. That could impact CTA enforcement, too.

For now, businesses covered by the CTA should get ready for the March 25, 2025, deadline and stay tuned for more regulatory updates.

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