Corporate Transparency Act Update: Supreme Court Lifts Injunction, Filing Requirement Still on Hold

In an 8–1 decision, on January 23, 2025, the United States Supreme Court (USSC) lifted the injunction that had blocked enforcement of the Corporate Transparency Act (CTA) since early December. However, following the USSC ruling, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) acknowledged that a separate but similar nationwide order issued on January 7, 2025, by a different federal district court in Texasremains in effect. 

Accordingly, the beneficial ownership information (BOI) reporting requirement of FinCEN remains enjoined, and reporting companies are not required to file BOI reports at this time. As part of its announcement, FinCEN confirmed that reporting companies may continue to voluntarily submit, but are not subject to liability if they fail to do so while the order remains in force.

You’re in good company if your head is spinning from all the “on again, off again” relating to the CTA. Unfortunately, it is not yet clear what will ultimately come of the CTA as there remain several cases before other district courts that have yet to rule on the CTA, and it is also unclear whether the Republican-controlled Congress will take up action to repeal or delay the enforcement of the CTA.

Here’s a summary of where enforcement of the CTA stands as of today:

Date	Action		Status	of CTA
January 24, 2025	FinCEN acknowledges separate nationwide order remains in effect, enjoining enforcement			Voluntary submissions only
January 23, 2025	USSC overturns injunction issued on December 3			Still on hold (USSC decision did not impact January 7 district court order)
January 7, 2025	Separate district court in Texas stays enforcement			On hold, pending review
December 27, 2024	FinCEN acknowledges order enjoining enforcement			Voluntary submissions only
December 26, 2024	U.S. federal appeals court vacates earlier decision			On hold, pending appeal
December 23, 2024	FinCEN extends BOI filing deadline			Filing deadline extended to January 13, 2025
December 23, 2024	U.S. federal appeals court reinstates enforceability			In force, filing deadline January 1, 2025
December 17, 2024	District court denies government request for a stay of the injunction			On hold, pending appeal
December 7, 2024	FinCEN acknowledges order enjoining enforcement			Voluntary submissions only
December 3, 2024	District court in Texas enjoins enforcement			On hold, pending appeal
January 1, 2021	Congress enacts CTA			Enacted

In light of the actions described above, we recommend that companies continue preparations to comply with the CTA, pending the outcome of the ongoing appeals.

As described in our prior newsletters, including the newsletter circulated on, Congress passed the CTA as part of an anti-money laundering package in the 2021 National Defense Authorization Act (NDAA), with the aim of curbing illicit financial activities, including tax evasion, money laundering, drug trafficking and terrorist financing. Under the CTA, many corporations, limited liability companies, limited partnerships and similar legal entities are required to report BOI to FinCEN.

For additional information relating to the CTA, visit .