Corporate Transparency Act Compliance Remains Voluntary — For Now

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland).

However, as a separate nationwide order issued by a different federal judge in Texas (Smith v. U.S. Department of the Treasury) still remains in place, reporting companies are not currently required to file beneficial ownership information with the Financial Crimes Enforcement Network (FinCEN), despite the Supreme Court’s action in Texas Top Cop Shop.

Reporting companies also are not subject to liability if they fail to file this information while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports. We will continue to update you if and when Corporate Transparency Act (CTA) compliance becomes mandatory, and we are also monitoring any changes that may result from the actions of the new White House administration.

Questions on beneficial ownership information reports and the CTA? Reach out to Robert Garner or a member of our Corporate group.