On March 2, 2025, the U.S. Department of Treasury announced that fines or penalties under the Corporate Transparency Act (CTA) will not be enforced against U.S. citizens or domestic reporting companies or their beneficial owners under the existing reporting deadlines and/or after forthcoming rule changes take effect at a later date.

The current position of this administration is that the CTA will never be enforced against U.S. reporting companies or their beneficial owners.

Pending finalization of new rules, the Treasury has also suspended enforcement against foreign reporting companies that would otherwise be required to report under the CTA. Accordingly, the Treasury plans to issue proposed rules later this year that will narrow the scope of the obligations under the CTA to foreign reporting companies only.

Taft will continue to monitor developments and implications of the CTA and provide additional alerts as information becomes available.