FWW Alert: CTA Landscape Changes – Again

12/26/2024

In a recent FWW Client Alert, we reported that enforcement of the federal Corporate Transparency Act ("CTA") was enjoined by a federal court in Texas on December 3, 2024. The CTA requires filing of reports containing significant personal details regarding business owners with the Financial Crimes Enforcement Network ("FinCEN") under the U.S. Department of the Treasury. The injunction in the Texas litigation was welcome news to many businesses throughout the country (as well as to many of us at FWW). As warned in our previous alert, however, the hammer could drop again. And it did.

On December 23, 2024, the U.S. Fifth Circuit Court of Appeals issued an order that stayed the nationwide preliminary injunction on CTA enforcement. In that ruling, the Fifth Circuit found the government met its burden to show that the nationwide injunction was not appropriate.

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