3 December 2024: The US District Court for the Eastern District of Texas issued a nationwide injunction on the CTA in connection with the case Texas Top Cop Shop, Inc. vs Garland.
5 December 2024: The Department of Justice, on behalf of the Department of the Treasury, filed a Notice of Appeal and issued a statement which said: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with the Financial Crimes Enforcement Network (“FinCEN”) and are not subject to liability if they fail to do so while the order remains in force.”
23 December 2024: The Fifth Circuit Court of Appeals granted a stay of the district court’s preliminary injunction enjoining the CTA, requiring reporting companies to once again file beneficial ownership information with FinCEN.
23 December 2024: The Department of the Treasury extended the CTA reporting deadlines, in recognition that reporting companies may need additional time to file.
26 December 2024: The Fifth Circuit merits panel reinstated the nationwide injunction blocking enforcement of the CTA in order to preserve the constitutional status quo while the merits panel considers the parties’ arguments.
26 December 2024: FinCEN issued a statement which said: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
25 March 2025: The Fifth Circuit Court of Appeals will hear oral arguments.
