Supreme Court Upholds Corporate Transparency Act But Required Filing Still On Hold

On January 23, 2025, the United States Supreme Court stayed an injunction in a case that would have blocked enforcement of the Corporate Transparency Act. However, the Financial Crimes Enforcement Network (FinCEN), which is responsible for enforcement of the Corporate Transparency Act, acknowledged in its most recent guidance that the requirement to file Beneficial Ownership Information reports is still on hold due to a separate nationwide injunction in another pending lawsuit. Companies that would otherwise be required to file a Beneficial Ownership Information report are not currently required to do, but they may continue to voluntarily submit reports. Companies that are waiting to file based on the current nationwide injunction should be prepared to monitor for future updates so that they can quickly comply with the requirement to file if the nationwide injunction is lifted.