Corporate Transparency Act (CTA) Enforcement Paused Yet Again 

In the ongoing saga of the Corporate Transparency Act (CTA) and its Beneficial Ownership Interest (BOI) reporting requirements, FinCEN has yet again paused enforcement.

On February 27, FinCEN announced that it will not impose fines, penalties, or take enforcement actions against companies that fail to file or update BOI reports by the current deadlines. This pause will remain in place until new deadlines have passed. These deadlines will be laid out by FinCEN in an interim final rule expected to be published by March 21 (which date had been set as the new filing deadline only 9 days ago). In addition to extending the deadlines, it also seems likely that FinCEN will attempt to expand the definitions and categories of exempt entities under the law. 

While FinCEN is putting the brakes on enforcement of the CTA for the moment, companies can choose to voluntarily report in the interim. 

Given that the penalties for failure to properly file under the CTA include criminal felonies, we feel it is important to keep our clients updated on the law, even if the seemingly constant status updates can be confusing. We will continue monitoring developments closely. In the meantime, if you have any questions about your reporting obligations, please do not hesitate to contact one of our Business and Finance attorneys.