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.
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 […]
President Trump’s Nomination of Brittany Bull Panuccio Restores EEOC Quorum
What the Commission’s New Majority Means for Workplace Enforcement and Employer Compliance On October 7, 2025, the U.S. Senate confirmed President Trump’s nomination of Brittany Bull Panuccio to a vacant seat on the Equal Employment Opportunity Commission (EEOC or the Commission). Commissioner Panuccio’s confirmation grants EEOC a quorum for the first time since President Trump’s […]
The Intersection of SEQRA Reform and New York’s Updated Building and Energy Codes: Impacts on Project Planning
As discussed in prior updates, Governor Hochul’s administration has proposed targeted adjustments to the State Environmental Quality Review Act (SEQRA) to reduce procedural delay for certain housing projects that do not present significant environmental impacts. These proposals are part of the Governor’s 2026 agenda and include targeted SEQRA exemptions, geographic eligibility limits, floodplain exclusions, and […]
Proposed SEQRA Updates Aim to Accelerate Housing While Maintaining Environmental Standards
New York State is pursuing a significant reform initiative aimed at reducing procedural delays associated with the State Environmental Quality Review Act (SEQRA) for certain housing projects. The proposal, which is part of Governor Kathy Hochul’s 2026 State of the State agenda under the “Let Them Build” initiative, seeks to create targeted exemptions from SEQRA […]
New Jersey Enacts Comprehensive Hemp-Derived Cannabinoid Product Framework: What Businesses Need to Know
On January 12, Governor Phil Murphy signed S4509 into law, ushering in a sweeping regulatory framework for hemp-derived cannabinoid products in New Jersey. The statute repeals prior provisions governing intoxicating hemp and aligns state law with newly enacted federal standards under 7 U.S.C. §1639o. This development marks a significant shift for manufacturers, retailers, and distributors […]
New AI Executive Order: What It Means for AI Regulation
On December 11, 2025, President Donald J. Trump signed an executive order titled Ensuring a National Policy Framework for Artificial Intelligence (Executive Order). According to the Trump Administration, the goal is to create a uniform federal approach to AI policy and reduce conflicting rules across different states. For businesses operating in the AI industry, the […]
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