The future of the Corporate Transparency Act remains uncertain. For now, reporting entities are not required to file Beneficial Ownership Information reports with the Financial Crimes Enforcement Network (FinCEN).

Despite the Supreme Court’s stay of one nationwide preliminary injunction in Texas Top Cop Shop, Inc. v. McHenry, a second injunction remains in place under Smith v. U.S. Department of the Treasury. FinCEN has confirmed that reporting obligations will not be enforced so long as the second injunction remains in place.

Reporting entities should be prepared to file Beneficial Ownership Information reports in short order as the matter continues to be litigated.