--- title: "Corporate Transparency Act Enforcement Resumes with Filing Deadline of March 21, 2025" canonicalUrl: "https://wyche.com/insights/blog/posts/corporate-transparency-act-enforcement-resumes-with-filing-deadline-of-march-21-2025/" excerpt: "Legal Update and Action Steps for Business Owners On February 17, 2025, U.S. District Judge Jeremy Kernodle lifted the preliminary injunction that had previously blocked the enforcement of the CTA. This decision reinstates the reporting obligations for certain business entities. Following Judge Kernodle’s ruling, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN)…
Read More" datePublished: "2025-02-25T09:57:30-05:00" dateModified: "2025-02-26T15:59:17-05:00" --- - Corporate Transparency Act Enforcement Resumes with Filing Deadline of March 21, 2025 [Home](https://wyche.com/) » Corporate Transparency Act Enforcement Resumes with Filing Deadline of March 21, 2025 [** Eleanor Winn Nordholm](https://wyche.com/author/enordholm/) ** ** ** # Corporate Transparency Act Enforcement Resumes with Filing Deadline of March 21, 2025 ### Legal Update and Action Steps for Business Owners On February 17, 2025, U.S. District Judge Jeremy Kernodle lifted the preliminary injunction that had previously blocked the enforcement of the CTA. This decision reinstates the reporting obligations for certain business entities. Following Judge Kernodle’s ruling, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a thirty-day extension of the filing deadline for most companies to March 21, 2025, to allow businesses more time to comply. We believe that CTA’s reporting requirements may continue to evolve. Congress is considering legislation to revise aspects of the CTA. The U.S. House of Representatives unanimously passed a bill to delay the reporting deadline until January 1, 2026 for businesses formed before January 1, 2024. The bill is currently in the Senate for review. FinCEN has also indicated it will assess its options to further modify reporting deadlines and intends to take steps to reduce the compliance burdens for reporting companies that it sees as low risk. However, there is no guarantee that either of these possible changes will take effect before the March 21, 2025 deadline, if ever. We encourage reporting companies to take the below steps regarding compliance with the CTA. #### Action Items for Business Owners In light of these developments, we recommend that business owners take the following steps promptly: Review Ownership Structures: - Identify all beneficial owners, including individuals with direct or indirect control over the company. - Document why those individuals meet the definition of a beneficial owner. Prepare to Submit Reports to FinCEN: - Gather the necessary information for each beneficial owner, including full legal name, date of birth, residential or business address, and a unique identifying number from a government-issued ID or passport. - Submit the beneficial ownership report to FinCEN by March 21, 2025 (or a later date if Congress, a court, or FinCen provides a later date for businesses such as yours). Implement Systems for Ongoing Compliance: - Establish procedures to monitor and report any changes in beneficial ownership promptly. - Designate responsible personnel to oversee compliance with the CTA. Consult with Legal Counsel: - Seek legal advice to answer questions about the CTA and to address any specific concerns related to your business. Please contact [Eleanor Nordholm](/cdn-cgi/l/email-protection#361653585944525e595a5b76414f555e531855595b) or your regular Wyche attorney for more information about Corporate Transparency Act compliance. * # Eleanor Winn Nordholm Eleanor focuses her practice on general corporate matters, internal investigations, and employment law. She routinely counsels clients on a variety of issues, ranging from day-to-day employment matters and contract negotiations to complex corporate governance issues. Prior to joining Wyche, Eleanor served as in-house counsel for a private college preparatory school in Brooklyn, New York, where she advised on a variety of corporate, commercial and employment matters.  She began her career serving as an Assistant District Attorney for the Bronx County District Attorney Office in New York where she prosecuted financial and fraud investigations for the Investigations Division. Eleanor, a Greenville native, is a graduate of the University of Virginia School of Law and Wesleyan University. She was a member of the Virginia Criminal Law Journal while in law school. As an advocate for international human rights issues, Eleanor currently serves on the board of Justice In Motion, an organization focused on migrant rights to ensure justice crosses borders. 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