Business Law Journal

Over the last several months, AALRR has tracked and reported on the changes to the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) reporting requirements.  On March 2, 2025, the U.S. Treasury Department issued a statement providing that it will not enforce any penalties or fines associated with the reporting requirements under the current deadlines. Additionally, Treasury will also not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners even after FinCEN’s upcoming rule changes take effect.  Click here to read our full alert.

An old advertising jingle urged consumers to “look for the union label.”  A union label, or “bug,” typically consists of a union symbol and a number which identifies a specific employer.  However, using a bug without permission can have legal repercussions. 

For those following recent developments regarding the Corporate Transparency Act, and its Beneficial Ownership Information reporting requirements, the last month has been a dizzying rollercoaster. As of the date of this alert, the nationwide injunction preventing the enforcement of the CTA and its BOI reporting requirements has been reinstated by the Fifth Circuit Court of Appeal, meaning that “Reporting Companies” (as defined in the CTA) are currently not required to file BOI reports. However, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) continues to accept voluntary BOI submissions.