Fifth Circuit Grants Stay in Texas Top Cop Shop v. Garland, Lifting Nationwide Injunction on the Corporate Transparency Act Enforcement

12.23.2024

In an unpublished order issued on December 23, 2024, the Fifth Circuit granted the Financial Crimes Enforcement Network’s (“FinCEN”) emergency motion for a stay of the nationwide preliminary injunction that blocked enforcement of the Corporate Transparency Act (“CTA”) pending appeal in the case of Texas Top Cop Shop, Inc. v. Garland. The Fifth Circuit’s stay of the preliminary injunction means that the nationwide injunction blocking enforcement of the CTA is no longer valid.  Based on its court filings, FinCEN expects reporting companies formed prior to January 1, 2024, to file their initial beneficial ownership information report no later than the January 1, 2025 deadline to comply with the CTA.

Our team will continue to monitor developments surrounding the CTA (including any appeal by plaintiffs to the U.S. Supreme Court) and will provide updates as they occur. Please do not hesitate to reach out to our team if you have any questions about your filing obligations under the CTA.

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Maynard Nexsen is a full-service law firm with more than 550 attorneys in 24 offices from coast to coast across the United States. Maynard Nexsen formed in 2023 when two successful, client-centered firms combined to form a powerful national team. Maynard Nexsen’s list of clients spans a wide range of industry sectors and includes both public and private companies. 

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