UPDATE: U.S. Department of the Treasury Terminates Enforcement of the Corporate Transparency Act
U.S. citizens and domestic companies will no longer be subject to the CTA or its reporting requirements.
Just under two weeks after the Financial Crimes Enforcement Network (FinCEN), an enforcement bureau within the U.S. Department of the Treasury (the "Treasury Department"), officially reinstated the Corporate Transparency Act (CTA), it looks like the CTA is once again dead in the water, possibly for good – at least for U.S. citizens and domestic companies.
In a statement released late last Sunday, the Treasury Department announced, in no uncertain terms, that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies (or their beneficial owners) associated with the "beneficial ownership information" (BOI) reporting requirements under the CTA.
The Treasury Department further noted that even when forthcoming changes to the CTA (as discussed in our prior update) take effect, they will still not be enforcing any related penalties or fines against U.S. citizens or domestic reporting companies (or their beneficial owners).
The Treasury Department also added that they will be "issuing a proposed rulemaking that will narrow the scope of the [CTA] to foreign reporting companies only." Oddly enough, it appears that as of the time of publication of this post, FinCEN has yet to formally acknowledge the Treasury Department's recent statement, as FinCEN's website still shows the following:
In any case, it would appear that the Treasury Department's recent statement puts an end to the long back-and-forth drama that has played out regarding the enforcement of the CTA, at least with respect to U.S. citizens and domestic companies (and their respective beneficial owners).
As to foreign companies doing business in the United States, however, it is presumed that the CTA (and its reporting obligations) will still continue to apply to those companies (and their respective beneficial owners).
We will continue to monitor further changes to the CTA closely. Please contact us if you have any questions.
Related People
Related Capabilities
Subscribe to receive timely legal insights directly in your inbox.
Featured Insights

In The News
Jun 26, 2026
Brian McGrath Discusses Far-Reaching Impact of a NY Foreclosure Ruling on Mortgage Industry

In The News
Jun 26, 2026
Jason Oliveri Discusses AI Companions in Elder Care and the Risks for LGBTQ+ Residents

Event
June 25-26, 2026
Todd Young Speaks on Importance of Financial Literacy to ESOP Culture

Press Release
Jun 25, 2026
Scott Seaman Appointed to DRI Center for Law and Public Policy’s Social Inflation Task Force

In The News
Jun 23, 2026
Michael Dowell Explores New OIG Compliance Expectations for MAOs

Press Release
Jun 23, 2026
Jennifer Driscoll Reappointed as the ABA Antitrust Law Section Co-Chair of Comments

Press Release
Jun 22, 2026
Hinshaw Named a Client Service Standout Firm in BTI Consulting Client Service A-Team 2026

In The News
Jun 22, 2026
Lucy Wang Discusses California Insurance Solvency Regulation Addressing Climate Risks

Press Release
Jun 22, 2026
Justyna Regan Appointed Co-Chair of the CBA’s International and Foreign Law Committee

Consumer Crossroads: Where Financial Services and Litigation Intersect
Jun 18, 2026
Three Key Mortgage Enforcement Developments for Lenders in Illinois



