Corporate Transparency Act Updates: Fifth Circuit Vacates the Stay and Preliminary Injunction Reinstated
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As previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (the “CTA”) and its reporting obligations. On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the preliminary injunction. Following the Fifth Circuit’s stay, the Financial Crimes Enforcement Network (“FinCEN”) released a statement granting an extension to the CTA year-end reporting deadline to January 13, 2025.

However, on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated their stay of the preliminary injunction in light of the expedited ruling expected on the merits of the preliminary injunction.

FinCEN has not yet issued a statement but it is anticipated that they will comply with the injunction as they did last time while allowing reporting companies to voluntarily submit reports. In light of ongoing uncertainty, KMK recommends that entities continue preparing their CTA reports and be prepared to file on short notice if the preliminary injunction is once again stayed or overturned.  

Tags: Corporate Transparency Act
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KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.

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