Corporate Transparency Act Reporting Suspension, What Business Owners Should Know

On January 1, 2021, the Corporate Transparency Act (CTA) was enacted by Congress. The CTA is the largest anti money laundering legislation passed since 2001. The CTA created a new reporting requirement for businesses, which began on January 1, 2024, requiring any formally established business that is not subject to an exemption to file a Beneficial Owner Information Report (BOIR) with the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCEN) bureau. These reporting requirements impact most businesses, regardless of industry.

The requirement has not stayed still, however. Beginning in late 2024 and continuing into 2025, the CTA's reporting requirement went through a series of court challenges, injunctions, and reversals that repeatedly changed whether and when businesses actually had to file. In early March 2025, the Treasury Department announced that it would not enforce penalties or fines against U.S. citizens or domestic reporting companies under the existing BOI reporting rule, and that it intended to issue new rulemaking narrowing the rule's scope to foreign reporting companies only. In practical terms, that suspended enforcement against most U.S. businesses, though the underlying statute itself was not repealed, and Treasury has continued working on formal rulemaking to make the narrower scope permanent.

As the Treasury Department announced this suspension of Beneficial Ownership Information reporting requirements under the Corporate Transparency Act, here is what that means for business owners.

What Business Owners Should Know

Willful failure to report complete or updated beneficial ownership information to FinCEN, or the willful provision or attempted provision of false or fraudulent beneficial ownership information, may still result in civil or criminal penalties, including civil penalties of up to $500 for each day that the violation continues, capped at $10,000, or criminal penalties including imprisonment for up to two years, where the underlying requirement still applies.

Given how much this requirement has moved, both because of litigation and because of ongoing agency rulemaking, business owners should not assume their obligations, or their exemptions, are settled based on what applied even a year ago. The safest course is to confirm your current status directly rather than relying on outdated guidance, including outdated guidance you may have received previously.

Next Steps

Stay up to date with relevant CTA developments by following Azarvand Tax Law on Facebook or LinkedIn. Please contact Azarvand Tax Law at 410-698-4005 or book a free consultation at AzarvandTaxLaw.com to confirm your current CTA filing status, to get started on the Beneficial Ownership Information Report filing process if one is still required for your business, or to get assistance with any other tax issue you or your business may be facing, including but not limited to tax collection, audits, or compliance checks.