As previously noted, we are continuing to monitor developments with the Corporate Transparency Act (“CTA”). The U.S. Court of Appeals for the Fifth Circuit reversed its own decision and vacated its lifting of the injunction that was previously issued by Judge Amos L. Mazzant III of the Eastern District of Texas. Accordingly, the nationwide injunction is again effective and any companies subject to the purview of the CTA are not currently required to comply with same. The Fifth Circuit noted, as part of its reversal, that the appeal of Judge Mazzant’s injunction will be handled in an expedited manner.

As such, we will continue to monitor this case and promptly advise of any further developments. If you have any questions, please do not hesitate to contact our corporate and regulatory enforcement groups.

For more information, please reach out to David Polazzi and Brian D. Waller.