Late on Dec. 26, the 5th Circuit vacated its earlier decision which reinstates the injunction until the Court can hear arguments.
This is a rapidly evolving situation and we will continue to post updates as they are available.
We don’t expect by the 5th circuit to lift the injunction until Jan. 6 at the earliest. In response to the initial 5th Circuit decision, FinCEN extended the CTA compliance deadline until Jan. 13.
If you have previously engaged Parsons to assist with your FinCEN filings, we will proceed as outlined in our original engagement. To engage Parsons to assist in compliance, please reach out quickly to the attorney you routinely work with, or, if you would like to contact the CTA team directly, call (406) 317-7220 or send an email to cta@parsonsbehle.com.
