To Our Clients and Friends:

On February 18, 2025, following a decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of Treasury, et al., 6:24-cv-00336 (E.D. Tex.), beneficial ownership information reporting requirements under the Corporate Transparency Act (“CTA”) are once again back in effect. The Financial Crimes Enforcement Network (“FinCEN”) is extending the deadline for most companies to comply by March 21, 2025.

In addition to the decision, FinCEN announced its intent to revise the beneficial ownership reporting rule to reduce the burden on low-risk entities.

If you have not requested your GCT attorney to assist you with CTA compliance, it will be assumed that you understand your reporting obligations and will handle your own reporting. In the meantime, if you have any questions 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.