OK – this has been a cray week!
To recap the events, on December 23, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit reversed a Texas district court order that had initially granted a preliminary injunction of the enforcement of the CTA. The Circuit Court’s order temporarily lifted the hold on the enforcement of the CTA and reinstated the BOI filing requirements.
The Financial Crimes Enforcement Network (“FinCEN”) released a statement within hours of the Fifth Circuit’s decision, extending the applicable filing deadlines. I covered those in the prior post.
However, on December 26, 2024, the full Fifth Circuit Court reversed the three-judge panel, reinstated the stay, and again halted the enforcement of the CTA nationwide while the case’s merits were under expedited appellate review. As a result, reporting companies are once more relieved of their BOIR obligations, and FinCEN’s new deadlines are no longer enforceable.
Stay tuned for future developments!!!