Authors
Mark M. Christopher
Director, Boston
mchristopher@goulstonstorrs.com+1 617 574 3513
David L. Coombs
Director, Boston
dcoombs@goulstonstorrs.com+1 617 574 3563
Gary M. Ronan
Director, Boston
gronan@goulstonstorrs.com+1 617 574 3593
Vaishali Goyal
Associate, Boston
vgoyal@goulstonstorrs.com+1 617 574 2242On February 27, 2025, the U.S. Treasury Department announced that it will not impose penalties on any failure to comply with the Corporate Transparency Act (“CTA”), and on March 2, confirmed that it will not enforce any penalties against U.S. citizens or domestic companies for failing to comply with the CTA by the March 21, 2025 deadline. The Department also plans to narrow the scope of the law’s reporting requirements to focus only on foreign companies, delaying enforcement until new rules are finalized.
In other words, submitting a beneficial owner report to FinCEN is effectively voluntary. Although these statements bring some clarity as to the future enforcement of the CTA for U.S. citizens and domestic companies, we cannot be certain what will occur with foreign companies.
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