Clifford Chance

U.S. Government appeals another injunction against enforcement of the Corporate Transparency Act -- FinCEN indicates possible changes

February 14, 2025

We continue to track the latest developments with respect to challenges to the Corporate Transparency Act and a continuing nationwide injunction against its enforcement that has recently been appealed by Department of Justice.

Although the Supreme Court has already stayed one nationwide injunction, an appeals process with respect to a second, separate nationwide injunction is now underway. In its motion papers, the U.S. Government indicates that the Financial Crimes Enforcement Network will re-assess application of the CTA with respect to "low-risk" businesses.

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