CTA UPDATE – Fifth Circuit Lifts Nationwide Preliminary Injunction – FinCEN Extends Filing Deadlines

Advisory
Written By Brandon Caroprese

January 1, 2025 CTA filing deadline extended to January 13, 2025

On December 23, 2024, the Fifth Circuit Court of Appeals lifted the District Court’s nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.).

Following the decision of the Court of Appeals, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on December 23, 2024 published an alert extending the deadline for companies that were in existence prior to January 1, 2024 and were in existence on or after January 1, 2024 to file their initial beneficial ownership information (BOI) reports from January 1, 2025 to January 13, 2025. As a result, the following CTA deadlines are once again enforceable against reporting.

Brandon Caroprese

Brandon Caroprese has advised alternative investment fund managers for more than 12 years on operational performance initiatives impacting their front, middle and back offices.  He has worked closely with COOs, CFOs, CTOs and CCOs to implement agile processes through mature change management that have helped their organizations transform into leading technology-driven organizations.

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