On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion by the federal government to stay the nationwide preliminary injunction that had suspended enforcement of the Corporate Transparency Act (CTA) and stayed its compliance deadlines, including the January 1, 2025, compliance deadline for reporting companies formed prior to January 1, 2024. 

This Legal Update explains the extended deadlines that the US Financial Crimes Enforcement Network (FinCEN) issued within hours of the ruling, notes how the plaintiffs have responded and the Fifth Circuit might further respond, and provides takeaways for companies that may be subject to the CTA’s reporting obligations. 

Read our Legal Update.