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

Consumer Crossroads: Where Financial Services and Litigation Intersect
May 14, 2026
Key Takeaways from the 2026 MBA Legal Issues and Regulatory Compliance Conference

Consumer Crossroads: Where Financial Services and Litigation Intersect
May 14, 2026
SCOTUS Confirms: Federal Courts Retain Power to Affirm or Vacate an Arbitration Decision

In The News
May 13, 2026
Hinshaw Contributes Chapters to “Wrongful-Death and Survival Actions” IICLE Handbook

In The News
May 12, 2026
Hinshaw GC Steve Puiszis Discusses Protecting Attorney-Client Privilege in an AI Age

Event
May 12-13, 2026
Mitchel Chargo Speaks on the Rapidly Evolving Cannabis Industry

Consumer Crossroads: Where Financial Services and Litigation Intersect
May 11, 2026
Tennessee Reaches Settlement with Mariner in Multistate UDAAP Enforcement Action

Press Release
May 11, 2026
Ali Degan Elected to the Fellows of the American Bar Foundation

Press Release
May 11, 2026
John Weedon Re-Elected to the Jacksonville Bar Association’s Board of Governors in 2026

Press Release
May 7, 2026
Hinshaw Recognized as a 2026 BTI Associate Satisfaction A-Lister Firm




