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

Press Release
Aug 6, 2026
Charles Townsend Named a Best Mentor Finalist in the 2026 ALM Texas Legal Awards

Webinar
Aug 5, 2026
April Toy Moderates HNBA Webinar on AI in the Practice of Law

Privacy, Cyber & AI Decoded Alert
Aug 5, 2026
2026 AI Compliance: Upcoming Laws Every Organization Needs to Know

Press Release
July 21, 2026 | Updated on August 4, 2026
Three Hinshaw Attorneys Named to the 2026 National Black Lawyers’ Top 40 Under 40 List

Healthcare Alert
Aug 3, 2026
Fixing the Emergency Refill Trap: What California’s AB 1587 Means for Pharmacies

Consumer Crossroads: Where Financial Services and Litigation Intersect
Jul 30, 2026
Should Text Messages be Considered “Calls” Under the TCPA? The Seventh Circuit Says No

Healthcare Alert
Jul 30, 2026
California Courts Sharply Curtail the MICRA Damages Cap in Nursing Home Litigation

Insights for Insurers Alert
Jul 30, 2026
Analyzing a Couple of Cases Involving Exclusions in D&O Policies

In The News
Jul 29, 2026
Hinshaw Authors Contribute Two Articles in Latest Edition of the CCFL Quarterly Report

Webinar
Jul 28, 2026
Cathy Mulrow-Peattie and Sabrina Janeiro Present on Legal AI Technology

In The News
Jul 27, 2026
Scott Seaman Discusses How the Insurance Industry Contributed to the 2026 FIFA World Cup


