CTA Update: No Fines

Last night (February 27, 2025), the Financial Crimes Enforcement Network (FinCEN) announced it will not take any enforcement action against companies that fail to meet the current filing deadlines for initial reports or for report updates.

Recently, FinCEN had established March 21, 2025, as the deadline to file Corporate Transparency Act (CTA) Beneficial Ownership Information Reports (BOIRs) for companies that had been waiting for a resolution to the nationwide injunctions. FinCEN had stated it would issue further information prior to March 21, 2025.

Current Status

Upcoming Regulations

FinCEN also stated it will:

• Issue an interim final rule prior to March 21, 2025, to formally extend CTA BOIR deadlines.

• Solicit public comments on potential revisions to existing BOIR requirements.

• Issue new CTA BOIR rules later this year.

These steps are necessary in the U.S. Federal regulation and rule making process to ensure public participation and to ensure the agency action is consistent with the law the agency was assigned to implement.

Next Steps

This is not an indication that CTA will be eliminated. CTA was created by the U.S. Congress and signed into law by the U.S. President. FinCEN is reviewing changes to how it will implement CTA BOI reporting.

For those of you who have filed, currently you will not be penalized for failing to submit updates to your BOIR. Keep track of any changes that would require an update.

For those of you who have not filed, you may proceed now or continue to wait.