On December 3, 2024, a federal district court in Texas issued a nationwide preliminary injunction blocking the Financial Crimes Enforcement Network (FinCEN) and the Treasury Department from enforcing the filing requirements of the Corporate Transparency Act (CTA). The court additionally issued a stay against the compliance deadline of January 1, 2025, for existing entities.

FinCEN has responded that as long as the preliminary injunction remains in effect:

• Reporting companies are not required to report Beneficial Ownership Information (BOI) to FinCEN; and
• Reporting companies will not be subject to liability for failing to report their BOI.

FinCEN also indicated that reporting companies may continue to voluntarily submit BOI reports.

Due to uncertainty of how this will unfold, any companies required to file that have not filed to date would be advised to continue to gather the required information for filing and be prepared to file. Clients may also want to consult with legal counsel on their specific situation.

Please reach out to your Miller Cooper advisor if you have any questions.