After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury announced its own intention to limit CTA enforcement to foreign companies.
On March 2, 2025, the Treasury Department declared that “it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either.” The Treasury Department also stated that its proposed rulemaking will narrow the scope of the Reporting Rule to foreign Reporting Companies only “in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.” For now, reporting companies in the U.S. can put reporting beneficial ownership information on the backburner until further notice.
McGuireWoods will continue to monitor developments and publish updates as litigation proceeds and new guidance is issued. For questions about the CTA or anti-money laundering compliance generally, including customer due diligence and beneficial ownership rules, contact the authors of this article or another McGuireWoods attorney you work with.