(In Japanese) On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a public notice announcing that “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines.” The announcement effectively suspended enforcement of FinCEN’s own March 21, 2025 reporting deadline, which it issued on February 18, 2025. FinCEN also announced that it intends to issue an interim final rule by March 21, 2025 that will extend reporting deadlines and will also solicit public comment on potential revisions to CTA reporting.

(In Japanese) The stays of the two nationwide injunctions pending appeals mean that beneficial ownership information (“BOI”) reporting under the CTA is once again in effect. The Financial Crimes Enforcement Network (“FinCEN”) issued a public notice yesterday confirming that the CTA is back in effect and extending the deadline for BOI reporting to March 21, 2025.