The Corporate Transparency Act – Penalties Suspended

March 6, 2025

Tonkon Torp LLP

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The Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement action for failing to file or update BOI reports by the current deadlines and that it intends to issue a new interim rule extending those deadlines. The U.S. Treasury further announced on March 2, 2025 that it will not enforce any penalties against U.S. citizens, domestic reporting companies, or their beneficial owners even after the anticipated interim rule from FinCEN extending the deadlines. Treasury also stated they will be issuing a proposed rulemaking that will narrow the scope to “foreign reporting companies” only. Both the interim rule from FinCEN and the rulemaking from Treasury will have a comment period.

This means that until more information is provided by FinCEN or Treasury, CTA BOI reporting requirements are again voluntary.

We will continue to monitor updates regarding the effectiveness of the CTA, pending litigation, and possible legislative changes and will provide updates as they become available. Please contact us if you need assistance in complying with the CTA.

If you have questions about the issues raised here, please contact Claire Brown, Jessica Morgan, or the attorney with whom you normally consult.

About Tonkon Torp
Tonkon Torp LLP is a leading business and litigation law firm serving public companies, substantial private enterprises, entrepreneurial businesses, and individuals throughout the Northwest. Tonkon Torp is celebrating its 50th year in business! See our History Timeline for more information, or visit tonkon.com.