In 2020, Congress passed the Corporate Transparency Act (CTA), which was signed into law by President Trump. The CTA gave authorization to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) to collect beneficial ownership information of entities conducting business within the United States and to share that information among government agencies, financial institutions, and financial regulators. The CTA authorized the Secretary of the Treasury, and by extension FinCEN, to develop procedures and standards to implement the CTA. Prior to the CTA going into effect in 2024, FinCEN issued rules and regulations regarding reporting and other requirements for complying with the CTA.
After various legal challenges, on March 2, 2025, the U.S. Department of the Treasury stated that it was suspending enforcement of the CTA, including the beneficial ownership information reporting requirements, for U.S. citizens and domestic reporting companies. The U.S. Department of the Treasury further stated that it expects to issue proposed rulemaking to narrow the scope of the CTA to foreign reporting companies only.
Without further guidance from the U.S. Department of the Treasury or FinCEN, it is difficult to advise on how to comply with the CTA. Therefore, until we receive the promised future guidance from FinCEN, we are currently advising clients that there is no need to file beneficial ownership information under the CTA.
If you have any questions about the CTA or beneficial ownership information reporting, please feel free to contact David Fitzgerald at (212) 573-8428 or dfitzgerald@sadis.com.
