On March 2, 2025, the Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens. 

Treasury said that it is preparing a proposed rulemaking to narrow the scope of the rule to foreign reporting companies only. “Foreign reporting companies,” under the present formulation, are entities (including corporations and limited liability companies) formed under the law of a foreign country that have registered to do business in the U.S. by filing a document with a secretary of state or any similar office. 

While the rule may be subject to legal challenge, as the narrowing proposed by the Treasury Department is inconsistent with the text of the CTA itself, it is not clear who, if anyone, would challenge the new proposed rules. Congress is also contemplating changes to the law. 

The determination from Treasury follows the February 17, 2025 decision out of the Eastern District of Texas in Smith v. United States Department of the Treasury, which lifted the last remaining nationwide preliminary injunction on enforcement of the filing deadline, following the Supreme Court’s stay of the injunction in Texas Top Cop Shop, Inc., et al. v. Merrick Garland, et al., earlier this year.

Passed in the first Trump Administration but implemented during the Biden presidency, the CTA — an anti-money laundering law designed to combat terrorist financing, seize proceeds of drug trafficking, and root out illicit assets of sanctioned parties and foreign criminals in the U.S. — faced legal challenges around the country, many of which are still pending before appellate courts.

Treasury has not announced what will happen to the information provided by entities that have already filed under the CTA. However, domestic companies and U.S. citizens are no longer under any obligation to keep that information up to date given the suspension of enforcement.