No Fines for Now But More Briefing Ordered Regarding the Corporate Transparency Act and Beneficial Ownership Information

March 12, 2025, in the Texas Top Cop Shop v. Bondi appeal case—the case on the Corporate Transparency Act (CTA) and the Beneficial Ownership Information (BOI) Reporting—the Judge issued an Order requiring additional briefing due this week.

Overall background for CTA and BOI—(CTA) implemented in 2021, mandates that many businesses operating in the United States report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) to combat illicit finance and protect national security. 

The Top Shop Case v. Bondi case has been the most recent on a ping pong of reporting and not reporting requirements and deadlines and/or deadlines but no fines for not making the deadline. Along those lines, on March 2, 2025, the Treasury Department announced the suspension of enforcement of the CTA against U.S. citizens and domestic reporting companies.

• The Department stated it will not enforce any penalties or fines associated with the BOI reporting rule under the existing regulatory deadlines.

• The Department will also not enforce penalties or fines against U.S. citizens or domestic reporting companies, or their beneficial owners after the forthcoming rule changes take effect.

• The Department expressed intent to issue a proposed rule that will narrow the scope of the rule to foreign reporting companies only.

• The Judge directed the parties in the case to file simultaneous letter briefs addressing the suspension’s impact on the appeal.

• We will keep you updated as that briefing is done and the judge issues an order in response.