March 13, 2025 – In the latest development in this on-going saga, the U.S. Treasury Department and the Financial Crimes Enforcement Network, (“FinCEN”), have suspended all Corporate Transparency Act (“CTA”) enforcement and reporting requirements indefinitely for domestic entities. As we have previously reported, many small firearms companies – those with twenty or fewer employees and annual gross sales or receipts of less than $5 million – originally faced a deadline of January 1, 2025, to make certain filings under the CTA. This deadline was suspended in early December 2024, due to a preliminary injunction entered by the U.S. District Court for the Eastern District of Texas. We invite you to review our prior Alerts of November 2, 2024 and December 10, 2024, for additional information regarding the CTA, its requirements, and potential penalties for violations, as well as the previous suspension of the filing requirements.

Now, as of March 2, 2025, the U.S. Treasury Department announced in a press release that it would not enforce penalties or fines against U.S. citizens or domestic reporting companies in connection with the Beneficial Ownership Information (“BOI”) reporting rule, a requirement under the CTA. After legal challenges and appeals, a U.S. District Court had previously extended the compliance deadline to March 21, 2025. With this latest development suspending all reporting obligations and enforcement, U.S. small businesses have no obligation to report by that deadline. 

The FinCEN website remains active and is still accepting BOI reports. However, no reports are currently required to be filed for any entities. Foreign companies will still be required to file BOI reports in accordance with the CTA, however, those entities will not face any fines or penalties until after a new deadline, which is expected to be issued by March 21st. For clarity, foreign reporting companies are entities formed under the laws of a foreign country that are registered to do business in the U.S.

“This is a victory for common sense,” said U.S. Secretary of the Treasury Scott Bessent. “[This] action is part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.”

Renzulli Law Firm will continue to monitor developments related to the CTA and any associated reporting requirements. If you have any questions about the CTA, please contact John F. Renzulli or Christopher Renzulli.