FinCEN Corporate Transparency Act filings shut down by the US District Court for the Eastern District of Texas
Under the Corporate Transparency Act (CTA), entities that were in existence before January 1, 2024 are required to file Beneficial Owner Reports (BOR) with the Financial Crimes Enforcement Network (FinCEN) before January 1, 2025. Requirements also exist that set forth the time frame for filing the report when a new entity is formed. On December 3, 2024, an injunction was issued by a federal court that applies nationwide. Under the injunction, no company may be held liable for failing to file a BOR. The federal government has appealed, and we are following all developments very closely. If you navigate to the FinCEN site, you will find the following:
BOI e-Filing Alert: Please note that beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury is appealing that order. In the meantime, reporting companies are not currently required to file a BOIR and are not subject to liability if they fail to do so while the applicable order remains in force.
However, reporting companies may still opt to file a BOIR.
The net result is that FOR NOW, entities are not required to file BORs and will not be penalized for failing to file while the injunction is in effect. If the government is successful, new filing date requirements will be put into effect. If the district court ruling stands and survives future challenges, the CTA FinCEN filing requirements never get resurrected. Watch for future updates.
Is Your New Jersey Business Subject To Extended Producer Responsibility Obligations in Other States?
Extended Producer Responsibility (EPR) has quickly transformed from a niche policy idea into a nationwide regulatory framework that directly affects companies of every size. Rather than viewing waste management as purely a municipal function, state EPR laws shift financial and operational responsibility for the collection, recycling, and disposal of products and packaging materials onto the […]
New Jersey’s “Protecting Against Forever Chemicals Act” Signed Into Law: NJ Businesses Face New Compliance Deadline
On January 12, Governor Murphy signed the “Protecting Against Forever Chemicals Act” into law. The new statute is designed to reduce public exposure to perfluoroalkyl and polyfluoroalkyl substances, commonly known as PFAS. These chemicals, often called “forever chemicals,” are used widely in consumer products for their water, oil, and grease resistance. They persist in the […]
NJDEP ADOPTS LAND USE RULES TO ADDRESS CLIMATE CHANGE IMPACTS
On January 20, 2026, the New Jersey Department of Environmental Protection adopted amendments to its land use regulatory program to address the risks posed by climate change to New Jersey residents, their property, and the natural environment. Called the Resilient Environments And Landscapes (“REAL”) Rules. Originally proposed in 2024, these regulations faced substantial opposition, prompting […]
New Mandatory Timelines for Review of Cooperative Purchase Applications
On January 29, 2026, the New York City Council enacted Local Law 58 of 2026, adding a new chapter to the New York City Administrative Code that imposes statutory deadlines on cooperative boards when reviewing purchase applications that require board approval. The law addresses longstanding concerns about protracted and unpredictable co-op approval timelines and will […]
New Jersey Appellate Division Affirms NJDEP Environmental Justice Rules – What Regulated Entities Need to Know
On January 5, 2026, the New Jersey Appellate Division issued a published decision in In the Matter of the Adoption of N.J.A.C. 7:1C, rejecting consolidated challenges filed by industry and labor petitioners to the New Jersey Department of Environmental Protection’s Environmental Justice Rules. The decision affirms NJDEP’s authority to implement New Jersey’s 2020 Environmental Justice […]
EEOC Enforcement Priorities Take Shape Under New General Counsel Leadership
On November 18, 2025, President Trump nominated M. Carter Crow, the Global Head of Labor and Employment at Norton Rose Fulbright LLP, to be General Counsel of the EEOC. Carter Crow focuses his practice on wage and hour litigation, contracts, and restrictive covenants. As of this writing, Carter Crow has yet to be voted out […]
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