On December 27, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the stay on a nationwide preliminary injunction in the ongoing Corporate Transparency Act (CTA) litigation. This decision effectively reinstates the injunction, thereby halting the enforcement of the CTA’s reporting requirements for now. Previously, the stay had allowed the government to proceed with implementing the law, which mandates that certain entities disclose their beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN).
With the stay vacated, the original injunction is back in place which bars enforcement of the CTA while the case continues through the courts. This ruling, coming just days after the original injunction was stayed, shows how fluid the situation with the CTA is. Businesses which are subject to reporting obligations should keep in mind the ever changing nature of the CTA’s enforceability and take appropriate steps to be prepared for what may come next.
*NOTICE: This blog is intended solely for informational purposes and should not be construed as providing legal advice. Please feel free to contact us with any questions you may have regarding this blog post.