On February 6, 2025, the Financial Crimes Enforcement Network (“FinCEN”) published an alert announcing that it has filed a Notice of Appeal in Smith v. U.S. Department of the Treasury, which enjoined the enforcement of Beneficial Ownership Information (“BOI”) Reporting requirements nationwide.

The Supreme Court of the United States stayed a nationwide injunction on January 23, 2025 in McHenry v. Texas Top Cop Shop, Inc. The Financial Crimes Enforcement Network (“FinCEN”) will now be allowed to enforce the filing requirements of the Corporate Transparency Act while the matter is pending in lower courts, meaning any business originally required to file BOI reports before January 1, 2025 must comply immediately.