By Jessica S. Kaczinski and Ian T. ReillyWhen we last left our heroes (on February 18, 2025), the U.S. District Court for the Eastern District of Texas granted Financial Crimes Division of the U.S. Department of Treasury (FinCEN) a stay order on the last remaining national injunction preventing the enforcement of the Corporate Transparency Act (CTA). As a result, BOI reporting requirements under CTA once again became enforceable, requiring a BOI filing no later than March 21, 2025, for any business entity formed prior to 2024, and it appeared all hope was lost.Now, in a plot twist worthy of resolving any cliffhanger, on March 2, 2025, FinCEN itself announced that it will suspend the enforcement of all penalties and fines tied to the CTA’s Beneficial Ownership Information (BOI) reporting requirements for U.S. citizens and domestic reporting companies. FinCEN also intends to issue a proposed rulemaking that will narrow the CTA’s application to only foreign reporting companies.Notably, this does not repeal, nullify or suspend the legal obligation for business entities to comply with the CTA mandates. Instead, the Treasury Department, of which FinCEN is a unit, has informed business entities that it will not enforce the penalties for failure to comply with the existing regulatory deadlines, and similarly pledges not to impose penalties on business entities even after forthcoming changes take effect.“This is a victory for common sense,” commented U.S. Secretary of the Treasury Scott Bessent, linking the changes to President Trump’s broader agenda to “unleash American prosperity” by curbing regulations that burden the backbone of the nation’s economy—small businesses.It is crucial to understand that, for now, the CTA itself and the new filing deadlines remain valid, enforceable law. The Treasury Department’s actions only put enforcement of any penalties for violating that law on hold, rather than revoking the BOI obligations entirely. As we have already seen through this saga, the only thing certain is that everything is subject to change.As always, our team is actively monitoring the evolving legal landscape surrounding the CTA, and we’ll keep you informed of any additional developments as they arise. We however caution you that each impacted business entity needs to make an independent decision on how it wants to proceed in this uncertain political and legal landscape. We strongly suggest you contact your Gross McGinley attorney to discuss this in more detail prior to making a decision regarding filing a BOI prior to the deadline.