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Government Relations & Public Policy

Fifth Circuit Reverses Course, Blocks Enforcement of CTA

December 27, 2024

There have been two new developments regarding the Corporate Transparency Act (CTA).  

  • Following the December 23 Fifth Circuit order lifting the injunction on CTA enforcement, the Financial Crimes Enforcement Network (FinCEN) has extended the filing deadline for companies in existence prior to January 1, 2024 to January 13, 2025. More information is available here.
  • In a surprise move, on December 27 the Fifth Circuit lifted (possibly temporarily) their order staying the District Court’s injunction of CTA enforcement. This means that for the moment, the CTA is again unenforceable, pending a hearing and decision by the Fifth Circuit’s merits panel. The timing on that remains unclear, but the government has requested an “expedited” review.

For more information contact Moutray McLaren at mmclaren@icsc.com.