Supreme Court Allows Enforcement of the Corporate Transparency Act (CTA): What It Means for Businesses

Yesterday, January 23, 2025, the Supreme Court enacted a stay to the pivotal federal anti-money laundering law, the Corporate Transparency Act (CTA), signaling a strengthened commitment to combating financial crimes in the United States. This decision reverses a lower court ruling that had paused CTA and its BOIR filing requirement, underscoring the judiciary’s support for robust regulatory measures.

The Case at a Glance

The case at the center of these changes, Texas Top Cop Shop, Inc., et al. v. Garland, et al., has sparked significant shifts in the implementation of the CTA:

• On December 23, 2024, a Fifth Circuit Court panel granted a stay of a prior injunction, reinstating the CTA’s enforceability and prompting FinCEN to issue updated filing deadlines.
• On December 26, 2024, a separate Fifth Circuit panel vacated the stay, reinstating the district court’s preliminary injunction and halting enforcement of the BOI reporting requirements.
• On January 23, 2025, at the federal government’s request, the Supreme Court issued a stay of the CTA as it works to prevail over the legal challenge in a lower court as it has in previous oppositions.

The stay by the Supreme Court reaffirms the CTA’s critical role in detecting and preventing illicit financial activity.

Simplify BOI Reporting with Harbor Compliance

While FinCEN has yet to announce a new filing deadline for reporting companies formed before January 1, 2024, reports are expected to be due in the coming weeks. We encourage organizations to file as soon as possible to avoid any delays or penalties. Resources like the Small Entity Compliance Guide and FAQs are available to help businesses navigate their obligations.

Businesses formed on or after January 1, 2025, only have 30 days from the date of formation to file their initial BOI report.

At Harbor Compliance, we go beyond providing guidance—we offer comprehensive tools and services to make BOI reporting effortless.

BOI Reporting Service: Compliance Made Simple

Our BOI Reporting Service streamlines the entire process:

• Guided Information Collection: Our secure system walks you through gathering the necessary details for your BOIR.
• Expert Report Preparation: Our specialists prepare and submit your report on your behalf, eliminating the hassle of using FinCEN’s occasionally unreliable BOSS portal.
• Annual Subscription Benefits: Includes up to four initial, updated, or corrected filings per year, all securely stored in our SOC-2-compliant portal for easy future access.

With Harbor Compliance, you’ll never have to worry about starting from scratch or losing track of past filings.