30
April
2025
Update on the Corporate Transparency Act (CTA)
The CTA has been a source of confusion and concern for many, but recent developments indicate a shift. Key changes and implcations for MidAtlantic Dealers.
If you have been following the Corporate Transparency Act (CTA), you’ve been on a rollercoaster for the last year. Thankfully, it looks like that rollercoaster is coming to an end. On March 2, 2025 the US Department of Treasury issued guidance that it will not be enforcing the CTA’s Beneficial Ownership Reporting (BOI) requirements against any US citizens or domestic reporting companies. The Treasury Department does not have the ability to repeal the act, only Congress can do that, but Treasury is working on a rule to narrow the scope of BOI Reporting requirements.
The CTA was passed by Congress in 2021 and was to begin enforcement on January 1, 2024. The goal of the CTA was to cut down on money laundering, terrorist financing, corruption, and tax fraud by having almost all for-profit entities disclose who owns or controls the company. In order to meet the CTA’s goal of cracking down on financial crimes, it required almost all small and medium sized businesses to file a beneficial ownership report within 30 days of being formed or January 1, 2025 for any company that existed prior to 1/1/24. The CTA required any changes in ownership or control to be reported within 30 days of change.
Almost immediately after being passed by Congress it was challenged as unconstitutional. The CTA has been stayed by various court temporary restraining orders and injunctions since March 2024 and a series of starts and stops in December 2024, leading to an incredibly confusion roll out.
What does this mean for MidAtlantic Dealers? If you are a US Citizen or your entity was created in the US, you currently will not be penalized for noncompliance. If you are not a US Citizen and your entity was formed outside the US (i.e. reinsurance company) you may still be subject to penalties and should file a BOI report.
If you have questions about the CTA or BOI reports, contact our general counsel, Allison Harrison at This email address is being protected from spambots. You need JavaScript enabled to view it. or by calling (614)440-1395.
