Corporate Transparency Act – LIMITED Enforcement?
March 14, 2025 | Barna, Guzy & Steffen, Ltd.
If you have been following the “life” of the Corporate Transparency Act (CTA), an anti-money laundering law passed by Congress under the first Trump administration, you’ll have noticed the court challenges and on again, off again status. Those court challenges are likely moot at this point, as the Treasury Department announced on Sunday, March 2 that it will not enforce penalties or fines related to the CTA against US Citizens or domestic reporting companies.
The CTA is a federal law that went into effect on January 1, 2024. The initial reporting deadline was December 31, 2024, with approximately 6.5 million filings made by that date. Estimates of the number of companies that should be filing exceed 30 million. Large companies and those in already regulated industries are exempt from filing. The actual filing is fairly simple, and the information is not public. Reporting has not been viewed as burdensome, although some companies have objected to being required to disclose ownership.
At this time, FinCEN is still accepting filings, but we anticipate that few domestic companies will now elect to make the required filings. However, if your company has any foreign owners or is not a domestic (US) created entity, penalties and fines will still apply if the filing is not made. Further action to narrow the scope of the CTA is expected.
Please contact the corporate department at Barna, Guzy & Steffen with any questions on this or other business matters.