Our recent Client Alert discusses that last week, a Texas federal district court judge in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex., Dec. 3, 2024) issued a nationwide preliminary injunction temporarily enjoining enforcement of the Corporate Transparency Act and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) regulations on Beneficial Ownership Information Reporting Requirements (BOI Reporting Requirements). As a reminder, FinCEN’s BOI Reporting Requirements went into effect on January 1, 2024, and require Reporting Companies to file a report with FinCEN that includes information about the Reporting Company, its Beneficial Owners, and its Company Applicants (BOI Report). In a public statement over the weekend, FinCEN confirmed that it will comply with the nationwide preliminary injunction and that Reporting Companies are not required to file BOI Reports while the injunction remains in effect. FinCEN noted, however, that Reporting Companies can continue to submit BOI Reports voluntarily. The U.S. Department of Justice, on behalf of FinCEN, filed a Notice of Appeal on December 5, 2024. While the scope of the appeal is not yet clear, Reporting Companies may wish to continue preparing their BOI Reports so that they are ready to file if it becomes necessary—for example, if the injunction is overturned or narrowed.