CTA UPDATE: Reporting Requirements under the CTA Continue to be Suspended despite Supreme Court Ruling

Timing is everything. Moments after sending our last update, FINCEN updated their website to advise that the reporting requirements remain on hold. “As a separate nationwide order issued by a different federal judge in Texas (Smith v. U.S. Department of the Treasury) still remains in place, reporting companies are not currently required to file beneficial ownership information with FinCEN despite the Supreme Court’s action in Texas Top Cop Shop. Reporting companies also are not subject to liability if they fail to file this information while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”

We will continue to update you as this matter progresses.