The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of Treasury made the CTA once again enforceable, FinCEN set a deadline of March 21 for reporting companies to submit beneficial ownership information.

In the Feb. 27 guidance, FinCEN stated that it “will not issue any fines or penalties or take any enforcement actions” against any reporting companies for failure to comply with the March 21 deadline until a forthcoming interim final rule creating new deadlines is adopted. FinCEN stated it intends to issue this interim final rule no later than March 21 and will solicit public comment on potential revisions to the reporting rules.

FinCEN will consider these comments as part of a notice of proposed rulemaking that it plans to issue later this year “to minimize the burden on small businesses while ensuring that BOI is highly useful to important national security, intelligence, and law enforcement activities” and to determine any modifications to the deadlines for reporting.

McGuireWoods will continue to monitor developments and publish updates as these cases proceed and new guidance is issued. For questions about the CTA or anti-money laundering compliance generally, including customer due diligence and beneficial ownership rules, contact the authors of this article or another member of the McGuireWoods’ Financial Services & Securities Enforcement, Government Investigations & White Collar Litigation, Healthcare, Tax & Employment Benefits, or Corporate & Private Equity teams.