Overview
- The appellate panel held the CTA facially regulates economic activity because corporations and LLCs are inherently commercial instruments.
- The court rejected a Fourth Amendment challenge, finding the law’s uniform, limited data requests are not unreasonable searches or seizures.
- The CTA requires reporting of names and identifiers for “beneficial owners” controlling at least 25% or exercising substantial control, as well as company applicants.
- Despite the ruling, a March Interim Final Rule from the Treasury Department currently exempts domestic entities from filing, leaving only foreign entities registered to do business in the U.S. obligated to report.
- The case was remanded for further proceedings, and while the CTA stands as constitutional, the filing scope could change if Treasury revises or rescinds the current exemptions.