After years of anticipation and speculation about the rollout, the Corporate Transparency Act (CTA) became effective on January 1, 2024. Just two months later, the future of the CTA was put into doubt. On March 1, 2024, the U.S. District Court for the Northern District of Alabama held, in National Small Business United d/b/a National Small Business Association v. Yellen, that the CTA is unconstitutional.
Many questioned whether this would be the end of the CTA. However, a detailed read of the decision out of the Northern District of Alabama and the response to the decision from Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) paints a more complicated picture. MSI’s NYC law member firm Moses Singer provides further insights.