Following a dizzying back and forth at the end of 2024 regarding the enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements, the second of two nationwide injunctions blocking the enforcement of the CTA was stayed/lifted on Tuesday, February 18th. This means the Financial Crimes Enforcement Network (FinCEN) can now enforce reporting obligations and deadlines on applicable reporting companies, which have been extended to March 21, 2025, for all initial, updated, and/or corrected BOI reports.

Notably, FinCEN has noted its intention to assess its options to further modify reporting deadlines as well as to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.