UPDATE: The U.S. Department of the Treasury Suspends Enforcement Under the Corporate Transparency Act

by Kent A. Brasseale, II and Heather M. Lobermann

On March 2, 2025, the U.S. Department of the Treasury (the Treasury) published a Press Release in which it announced that the Treasury will no longer enforce any fines or penalties associated with failure to comply with the required Beneficial Ownership Information Report (BOIR) under the Corporate Transparency Act (CTA).

The Treasury is considering changes to the rules governing enforcement of the CTA. In this March 2 Press Release, the Treasury stated that the Treasury, following the revised rulemaking, will not require U.S.-based companies to comply with filing BOIRs under the CTA. Instead, the Treasury proclaimed that the CTA shall henceforth be required only by foreign entities.

The Treasury has expressed its commitment to issue the revised rules governing enforcement under the CTA by the current deadline most entities have to file the BOIRs: March 21, 2025. Stay tuned for more information following the Treasury’s updated rulemaking.

What Should We Do Now?

In light of the March 2 Press Release, entities that have not yet filed the BOIR can refrain from filing. We would still advise all entities currently required to file a BOIR under the law to prepare all necessary documentation for filing. The status of the CTA has been in a near-constant state of flux for over a year. Until a final rule is issued from the Treasury, the information proclaimed in the March 2 Press Release is subject to change.

How Can KDDK Help?

Contact attorneys Kent (“KAB”) Brasseale, II at kbrasseale@kddk.com or Heather Lobermann at hlobermann@kddk.com, or by phone at (812) 423-3183, for questions and assistance regarding the CTA.

Where to Read More about the Corporate Transparency Act?

KDDK has written numerous articles on the Corporate Transparency Act and its evolution as it progressed through the courts:

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