Further Guidance on the Corporate Transparency Act

As part of the ever-changing guidance on the Corporate Transparency Act (“CTA”), new guidance was released on March 2, 2025 that states the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) will suspend enforcement of the CTA as to U.S. companies and U.S. citizens, and reiterates that there will be no fines or penalties associated with failure to report beneficial ownership information (”BOI”).  Notably, in this March 2, 2025 guidance, the U.S. Department of the Treasury has also indicated that existing BOI reporting requirements will be further narrowed in scope and only apply to foreign reporting companies.  The press release can be found here: Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies | U.S. Department of the Treasury

As a result of the latest comments by the U.S. Department of the Treasury, we recommend that you discuss with legal counsel the best strategy in addressing CTA compliance.