On Jan. 24, 2025, FinCEN released a statement (screenshot below) acknowledging that the Corporate Transparency Act (CTA) remains enjoined given yet another injunction that has relieved business owners across the nation from Beneficial Ownership Information (BOI) reporting obligations under the CTA. In Samantha Smith and Robert Means v. US Department of the Treasury, et al., Case No. 6:24-cv-336-JDK, the United States District Court for the Eastern District of Texas issued an injunction against the CTA and its Reporting Rule on Jan. 7, 2025. This injunction remains in effect despite a Jan. 23, 2025, ruling from the United States Supreme Court, which granted a stay of the injunction issued in the Texas Top Cop Shop, Inc. v. McHenry (previously Texas Top Cop Shop v. Garland) December 2024 case from the United States District Court from the Eastern District of Texas.

As noted above, FinCEN has declared that companies are not currently required to file beneficial ownership information and will not be subject to liability for failure to do so while the injunction remains in effect.