TEMPORARY HALT ON CTA AND BOI FILINGS!

The district court’s injunction against the CTA represents a significant legal development with broad implications for businesses nationwide. While the ruling temporarily halts compliance obligations, the final outcome of this case remains uncertain. Businesses should stay informed and proactive as the legal battle over the CTA unfolds. Given that (i) the CTA and its Reporting Rule have received a great deal of interest from the business community and judiciary, (ii) a new Congress and administration will take office in the coming year, and (iii) the civil and criminal penalties for noncompliance can be severe, reporting companies and their beneficial owners should, at a moment’s notice, still be prepared to comply with the Reporting Rule — before the January 1, 2025 deadline — in case further judicial or legislative developments revive the requirement to comply. Furthermore, in case the injunction runs past January 1, 2025, reporting companies should be prepared to comply at a moment’s notice in case the injunction is overturned thereafter.