12/18/2024
In Texas Top Cop Shop, Inc. v. Garland, Judge Amos Mazzant issued a preliminary injunction that temporarily suspends enforcement of the CTA. The injunction applies nationwide and prevents reporting companies from complying with the CTA’s reporting requirements. The government appealed the order, which could result in a stay or reversal of the injunction. The appeal could be heard and decided before the end of 2024. While the injunction is in place, companies are not required to file BOIRs, but FinCEN is still accepting them. Companies can choose to file if they want to. However, it’s recommended that companies continue to gather information to prepare BOIRs.