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Corporate Transparency Act: Enforcement Limited to Foreign Reporting Companies
Print PDFThe Corporate Transparency Act (CTA), an anti-money laundering law designed to bring transparency to the control and ownership structures of companies operating within the U.S., has seen several fits and starts over the past several months.
Most recently, the U.S. Department of the Treasury (U.S. Treasury), whose Financial Crimes Enforcement Network (FinCEN) is charged with enforcement of the CTA, has announced that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies, or their beneficial owners, for their failure to file required information under the CTA. At the same time, the U.S. Treasury announced its intent to issue revised rules on or before March 21, 2025, which would limit enforcement of the CTA to foreign reporting companies. This development functionally amounts to an indefinite reprieve from the CTA for U.S. companies.
In addition to FinCEN’s anticipated guidance as to the CTA, we also expect developments from both the legislative branch, in light of Congressional bills to delay or set aside the CTA, and the judicial branch, with various lawsuits challenging the constitutionality of the CTA still ongoing.
If you would like additional information, please contact your Nutter attorney at 617.439.2000.
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