On December 23, 2024, the Fifth Circuit Court of Appeals granted the Department of Justice’s motion to lift the December 3, 2024 injunction issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc., et al. v. Garland, et al. Reporting companies are again required to file beneficial ownership information reports with the Financial Crimes Enforcement Network (FinCEN). The original deadline for some reporting companies was January 1, 2025; however, FinCEN has extended the deadline for certain companies to accommodate this change:

• Companies created or registered prior to January 1, 2024, now have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
• Companies created or registered in the U.S. on or after September 4, 2024, with original filing deadlines between December 3, 2024, and December 23, 2024, now have until January 13, 2025 to file.
• Companies created or registered in the U.S. between December 3, 2024, and December 23, 2024, have an additional 21 days to file.

FinCEN also notes the following special cases:

• Reporting companies eligible for disaster relief may have extended deadlines beyond January 13, 2025. These companies should abide by whichever deadline falls later.
• As indicated in the alert “Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.),” plaintiffs in National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.)—namely, Isaac Winkles, reporting companies for which Isaac Winkles is the beneficial owner or applicant, the National Small Business Association, and members of the National Small Business Association (as of March 1, 2024)—are not currently required to report their beneficial ownership information to FinCEN at this time.

Note that for companies formed on or after January 1, 2025, the deadline remains 30 days after receiving actual or public notice that their creation or registration is effective.