Once again, the Corporate Transparency Act (“CTA”) reporting requirements for reporting companies have been suspended and the previously noted deadlines are no longer applicable.
On March 2, the Treasury Department announced that it will not enforce any penalties or fines associated with beneficial ownership information (“BOI”) reporting requirements under the existing regulatory deadlines, nor will it enforce any penalties or fines against U.S. citizens, domestic reporting companies or their beneficial owners following the rule change. The Treasury Department also previewed that it will be proposing another rule change to narrow the scope of BOI reporting obligations to foreign reporting companies. Such rule change, the Treasury Department reasons, will advance public interest and eliminate undue burden on small American businesses.
Prior to the Treasury Department’s announcement, on February 27, FinCEN also announced that it would not issue any fines or penalties or take any other enforcement action against any companies based on any failure to file or update BOI reports pursuant to the CTA by the current deadlines. Furthermore, FinCEN announced that no fines or penalties would be issued, and no enforcement actions would be taken until a forthcoming interim final rule becomes effective, noting intentions of issuing such an interim final rule no later than March 21, 2025.
Please reach out to our CTA committee, Howard Davis, Aylin Daldal or Gary Kan, for any questions.
