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In a recent update on March 2, 2025, the U.S. Department of the Treasury expanded on FinCEN’s recent decision to halt enforcement of the Corporate Transparency Act (CTA). Over the past few weeks, there have been numerous updates regarding the CTA, and this latest announcement might be the most significant yet.
The department not only reaffirmed that penalties or fines will not be imposed until a new reporting rule is released but also stated that “no penalties or fines will be imposed on U.S. citizens, domestic reporting companies, or their beneficial owners once the forthcoming rule changes take effect.” The Treasury’s press release revealed that the new reporting rule will only target foreign reporting companies.
Practical Implications
For now, the CTA is effectively on hold again. Although a new reporting rule is expected to be announced and finalized this year, it remains unclear how enforcement of that rule will be implemented.
It’s important to also note the legal status of the CTA. If courts uphold its constitutionality and Congress does not repeal the law, the CTA will technically remain in effect, even if it isn’t actively enforced. A shift in policy, a change of administration, or changes in enforcement priorities could lead to renewed enforcement of the CTA and its reporting requirements against U.S. citizens and domestic reporting companies.
Looking Ahead
Given the political uncertainty under the new administration, the future of CTA enforcement remains unclear. Shifts in policy or changes in enforcement priorities could lead to renewed focus on the CTA. While professionals and companies should stay informed as the situation evolves, they may not need to pay as close attention as they have in recent months.
You can read the full press release from the Department of the Treasury here.
