This is still a developing matter. On December 23, 2024, the Fifth Circuit issued an order that has the effect of reinstating FinCEN’s ability to enforce the CTA and the looming December 31 deadline to file reports for any required entity formed prior to January 1, 2024. FinCEN has yet to update its website with any official communication, reaction, or new guidance regarding the ruling. The FinCEN website has continued to accept filings, and it is currently up and running.

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