The U.S. Department of the Treasury announced on Sunday March 2, 2025 that it will “not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners [ …]” This press release from Treasury followed the February 27, 2025 release wherein FinCEN committed to (i) extending the existing March 21, 2025 filing deadline, (ii) re-writing the reporting rules (and opening the process to public comment) and (iii) not enforcing the CTA based on violations of the extended deadlines.

Thus, once the new reporting rules have been issued, and absent further change, U.S. citizens or domestic reporting companies or their beneficial owners are not expected to have reporting obligations. Non-U.S. entities that have filed in a U.S. jurisdiction to do business are expected to have a CTA filing obligation; however, for now, the scope of such an obligation has not been set, and the applicable deadline has not been determined.

As suggested by Treasury and FinCEN, subject to the additional commitments, the obligations (and applicable timelines) are as follows:

There will be additional developments in this space, so it is necessary to pay careful attention to CTA updates as they develop.

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