Additional Developments Regarding Corporate Ownership Reporting

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert on December 27, 2024, regarding Beneficial Ownership Information. In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports. On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction, meaning that reporting would once again be required, and deadlines for reporting were extended to January 13, 2025. However, on December 26, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024 order. As of December 26, 2024, reporting companies are not currently required to file beneficial ownership information with FinCEN.