Following up on our most recent blog post on developments regarding the enforcement date for the Corporate transparency Act (“CTA”), on December 26, 2024, the Fifth Circuit Panel that will ultimately be handling the merits of the appeal from the District Court issued an order vacating another order by a different Fifth Circuit panel on December 23, 2024 that had stayed the U.S. District Court for the Eastern District of Texas’ nationwide injunction on the beneficial ownership reporting obligations under the CTA. The aim of the rapid reversal is to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments. As a result of the December 26, 2024 order, the reporting obligations under the CTA are, now again, stayed for all reporting companies pending the outcome of the U.S. Government’s expedited appeal to the Fifth Circuit, as initially discussed in our blog post earlier this month. The Fifth Circuit’s order indicated a briefing schedule for the appeal would be issued forthwith.
We are continuing to monitor the situation, and will provide further updates when they become available.
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About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
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