As previously reported, the United States Court of Appeals for the Fifth Circuit revived the immediate enforceability of the Corporate Transparency Act (CTA). On December 26, 2024, the Fifth Circuit vacated the stay of a preliminary injunction against enforcement of the CTA. This order reinstates the December 3rd, 2024 injunction issued by the District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc. v. Garland.

This means that enforcement is currently halted. The injunction prohibits FinCEN from taking any enforcement actions related to the CTA until further notice. As such, companies are currently not required to file their Beneficial Ownership Report with FinCEN by the revised deadline of January 13, 2025.

If you have any questions or need assistance, please do not hesitate to contact us.