Clifford Chance
Treasury Shifts Stance on CTA Reporting Requirements Following FinCEN's Statement Assuring That There Will Be No Enforcement of Current CTA Deadlines
March 11, 2025
We continue to track the latest developments with respect to challenges to the Corporate Transparency Act ("CTA"). Although the nationwide injunctions against its enforcement have been lifted, and the CTA is now back in effect, whether and how it will be enforced and reshaped is under question after a March 2, 2025 announcement by the U.S. Department of the Treasury ("Treasury") signaled an intention to narrow the scope of the CTA requirements through a forthcoming rulemaking. Treasury also suggested that it will not enforce the CTA against "U.S. citizens and domestic reporting companies."
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