On December 27, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the earlier order of December 23, 2024, granting a stay of the preliminary injunction. For more detail and previous updates on the Corporate Transparency Act, see our December 24, 2024, Alert “Corporate Transparency Act Enforcement Resumes with Extended Deadlines.”

Accordingly, as of December 27, 2024, reporting companies are not currently required to file beneficial ownership information (BOI) with Financial Crimes Enforcement Network (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 BOI reports with FinCEN.

The case is Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), the U.S. District Court for the Eastern District of Texas, Sherman Division.