To Our Clients and Friends:

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry, formerly Texas Cop Shop V. Garland).

A separate nationwide order issued by a different federal judge in Texas (Smith v. U.S. Department of the Treasury) remains in place. At this time, reporting companies are not currently required to file beneficial ownership reports despite the Supreme Court’s ruling in Texas Top Cop Shop.

Please note that reporting companies are not subject to liability if they fail to file a report while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports in the meantime.

If you have any questions about CTA compliance in light of this update, please contact the GCT attorney with whom you work. GCT will continue to monitor developments and provide updates as they become available.