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.
New Jersey Data Centers at a Crossroads? Vineland's Self-Powered AI Campus and Monroe Township's $300 Million Zoning Battle
Disputes surrounding New Jersey data centers are intensifying as the State positions itself as a leader in artificial intelligence, cloud computing, and advanced technology infrastructure. Recent proceedings in Vineland and ongoing litigation in Monroe Township illustrate the growing tension among local land-use control, energy concerns, environmental impacts, and statewide economic development objectives. The outcomes of […]
NJ Election Communications Under ELEC Review: What Incumbents Should Know
On August 5, New Jersey entered the 90 days before the November 3, 2026 general election. For incumbent officials who are on the ballot, that date activated a longstanding ELEC regulation, N.J.A.C. 19:25-10.10, under which NJ election communications rules can treat routine governmental updates as reportable political activity. Our Public Law group first covered this […]
Senate Continuing Resolution Would Delay Upcoming Federal Hemp Restrictions
Industry Faces Continued Uncertainty Ahead of the November 2026 Deadline The U.S. Senate has introduced a funding measure that would temporarily delay implementation of sweeping federal hemp restrictions scheduled to take effect on November 12, 2026. While the proposal provides a potential short-term reprieve for hemp-derived cannabinoid manufacturers, retailers, distributors, and investors, it does not […]
New Jersey Data Center Bans Draw a Second Developer Lawsuit, and a $300 Million Damages Claim
Update (August 2026): For the latest developments in this matter, including the Vineland Planning Board’s review of a self-powered AI campus and Monroe Township’s motion to dismiss, see our updated client alert. New Jersey municipalities are moving aggressively to keep data centers out, and developers are beginning to push back in court. Within the span […]
New Jersey Enacts Sweeping Data Broker Law That Could Affect More Businesses Than Expected
On June 30, 2026, Governor Mikie Sherrill signed Assembly Bill 5328 (P.L.2026, c.25), establishing a comprehensive regulatory framework governing data brokers and certain businesses that sell or license personal information. While the New Jersey data broker law has garnered attention for imposing annual registration fees that can reach $1.5 million, its significance extends well beyond […]
New Jersey Enacts 'Power NJ Act' as Gov. Sherrill Signs Advanced Nuclear Procurement Into Law
Following near-unanimous passage by both the Assembly and Senate, Governor Sherrill has signed the Power NJ Act (S4296/A4881) into law, formally establishing New Jersey’s first statutory pathway for procuring advanced nuclear energy facilities. As we reported when the Legislature passed the bill, the Power NJ Act directs the New Jersey Board of Public Utilities (BPU), […]
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