Alerts1.24.25

CTA Still Enjoined: U.S. Supreme Court Grants Stay, But Second Nationwide Injunction Remains in Effect


Highlights

The U.S. Supreme Court granted a stay of an injunction suspending enforcement of the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting rule

A separate nationwide injunction issued by a different federal judge continues to enjoin enforcement of the CTA

Obligations under the CTA to file BOI reports currently cannot be enforced by FinCEN


Continuing a series of rapid-fire legal developments regarding the Corporate Transparency Act (CTA), on Jan. 23, 2025, the U.S. Supreme Court granted a stay of the amended injunction issued Dec. 5, 2024, by the U.S. District Court for the Eastern District of Texas. However, a separate nationwide injunction – issued by a different federal judge in Texas on Jan. 7, 2025 – continues to enjoin the Financial Crimes Enforcement Network (FinCEN) from enforcing the CTA’s beneficial ownership information (BOI) reporting deadlines.

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