By Matthew Batista

New FinCEN rule eases CTA reporting for U.S. firms. Foreign companies must act by April 21. Here are new key compliance insights.

Matthew D. Batista


SAN DIEGO, CALIFORNIA – In our last client alert on March 11, 2025, we noted that the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) was considering yet another policy change concerning the Corporate Transparency Act (“CTA”) and the requirements of reporting companies to report on their beneficial ownership.

As of March 21, 2025, FINCEN indeed promulgated a new interim final rule (“Interim Rule”), which now largely exempts all domestic entities from their CTA reporting requirements. Entities formed outside of the U.S., though doing business in the U.S., and thus generally required to register to do business in the U.S. jurisdictions where such entities are in fact doing business, must still file CTA Beneficial Ownership Information Reports (“BOIRs”). If such foreign entities were formed prior to March 21, 2025, such entities must file their BOIRs within thirty (30) days, thus no later than April 21, 2025.

Foreign entities formed after March 21, 2025 must file within thirty (30) days of formation. However, in either case for such foreign reporting entities, BOIRs concerning U.S. beneficial owners are not required to be reported on, only such entities’ foreign beneficial owners.

Klinedinst PC will continue to monitor the CTA and news from FinCEN, along with CTA related litigation that may affect the compliance requirements for our clients. If you have any questions or comments regarding the CTA and BOIRs, you are encouraged to reach out and consult with counsel.

To learn more about the CTA, or to contact a member of the transaction team, please visit:

klinedinstlaw.com/practice/corporate-transparency-act

Note

This update on the CTA is provided as-is and does not constitute legal advice, and should not be relied upon as such. You are encouraged to consult with your attorney with any questions.

About Klinedinst

Klinedinst is the go-to firm for clients looking for litigation, trial experience, transactional representation, and legal counsel. The firm’s offices in Irvine, Las Vegas, Los Angeles, Sacramento, San Diego, and Seattle service clients across the West, handling matters in California, Washington, Oregon, Nevada, and Arizona. What sets Klinedinst apart is the relationship our attorneys foster with each and every client. Klinedinst lawyers are indispensable strategic partners to business leaders, helping to achieve business objectives and create proactive solutions to resolve the many legal challenges that businesses are confronted with every day.  Whether vigorously advocating for business clients in court, or guiding business transactions and negotiations, Klinedinst is the trusted legal advisor to have by your side.

By Matthew Batista

FinCEN to Revise CTA Rules by March 21, 2025 – Beneficial ownership reporting requirements could change again, potentially easing compliance for U.S. entities. Here are the latest updates.

Matthew D. Batista


SAN DIEGO, CALIFORNIA – The Corporate Transparency Act (CTA) has been a hot topic in the legal industry since its enactment in 2021. However, ongoing legal challenges and shifting regulations have made compliance a moving target for law firms and businesses alike.

The Corporate Transparency Act – The Corporate Transparency Act (the “CTA”) was originally enacted in 2021 to combat and prevent various financial crimes and illicit activities in the U.S. by requiring most entities operating in the country to report on both their beneficial ownership and on those who exert significant control over an entity and its operations. Most entities were or are required to file beneficial ownership information reports (“BOIRs”) in either 2024 or 2025, but the CTA has continued to experience legal and regulatory shifts, causing confusion for reporting entities. This client alert serves to update our clients on the present status of the CTA and BOIRs.

Recent Regulatory Changes

January 23, 2025 – Supreme Court Lifts CTA Injunction: As of January 22, 2025, a nationwide injunction had been in place against the CTA and its enforcement. On January 23, 2025, however, the U.S. Supreme Court ruled that the Federal Government may enforce the CTA.

January 24, 2025 – BOIRs are Optional per FinCEN: On January 24, 2025, while considering the Supreme Court’s ruling and in light of a separate nationwide injunction regarding the CTA that remained in effect, the Department of Treasury’s (the “Treasury”) Financial Crimes Enforcement Network (“FinCEN”) issued guidance that CTA BOIRs were merely optional filings for the time being.

February 18 and 19, 2025 – Lifting of Injunction; Extension of BOIR Timeline: As of February 18, 2025, the remaining nationwide injunction was lifted, clearing the way for enforcement of the CTA, once again requiring BOIRs from reporting companies, and extending the reporting deadline to March 21, 2025 for most entities.

February 27, 2025 & March 2, 2025 – Treasury/FinCEN Enforcement Suspension: However, as of February 27, 2025 (for FinCEN) and March 2, 2025 (for the Treasury), the Treasury and FinCEN announced that such entities would not enforce the CTA or impose any penalties for CTA non-compliance. Further, each entity noted that a revised rule would be introduced by March 21, 2025, which is also currently the extended BOIR reporting deadline, which intends to restrict BOIRs to foreign entities operating in the U.S. only, in order to ease the burden on U.S. small businesses and U.S. citizens.

General Status and Recommendations

Present Status: Presently, there is no nationwide injunction legally preventing enforcement of the CTA. However, given the most recent guidance from the Treasury and FinCEN, the CTA and BOIRs will not be enforced by the March 21, 2025 extended BOIR deadline, and instead, a new, more limited rule will be introduced by such date, which will likely also include a further extended reporting deadline.

Stay Informed, Be Prepared: Given the contradictory rulings and guidance along with other continued legal challenges, the best thing entities can do is to say informed and be prepared to comply with the CTA and to file BOIRs if needed. Our attorneys at Klinedinst PC can help you navigate your unique situation relative to the CTA and BOIRs.

The Corporate Transparency Act remains in flux, with shifting regulations and ongoing legal challenges creating uncertainty for businesses. Staying informed and prepared is key, and legal counsel can help navigate compliance as new rules emerge.

To learn more about the CTA, or to contact a member of the transaction team, please visit:

klinedinstlaw.com/practice/corporate-transparency-act

Note

This update on the CTA is provided as-is and does not constitute legal advice, and should not be relied upon as such. You are encouraged to consult with your attorney with any questions.

About Klinedinst

Klinedinst is the go-to firm for clients looking for litigation, trial experience, transactional representation, and legal counsel. The firm’s offices in Irvine, Las Vegas, Los Angeles, Sacramento, San Diego, and Seattle service clients across the West, handling matters in California, Washington, Oregon, Nevada, and Arizona. What sets Klinedinst apart is the relationship our attorneys foster with each and every client. Klinedinst lawyers are indispensable strategic partners to business leaders, helping to achieve business objectives and create proactive solutions to resolve the many legal challenges that businesses are confronted with every day.  Whether vigorously advocating for business clients in court, or guiding business transactions and negotiations, Klinedinst is the trusted legal advisor to have by your side.

Klinedinst PC’s BE ICONS presents an exclusive event to empower legal professionals and women in law, while addressing issues surrounding imposter syndrome, leadership presence, and strategies for long-term career success.

SAN DIEGO, CA – Women in corporate law are breaking barriers, leading with resilience, and shaping the future of the legal industry. However, many still face challenges when it comes to building confidence, overcoming imposter syndrome, and owning their strengths in leadership roles.

To help women lawyers develop executive presence, strengthen leadership strategies, and navigate common career challenges, Klinedinst PC’s women’s affinity group, BE ICONS (Building Engagement, Inclusion, and Connections to Optimize Networking and Success), is hosting a free Women’s History Month webinar: “Trailblazers.”

Grace Gower

Trailblazers will be moderated by Klinedinst Shareholder Grace Gower, who has represented a wide variety of clients in diverse areas of law, primarily involving complex litigation matters, including business disputes, contractual disputes, commercial and residential real estate, and construction matters for over a decade.  She has also represented both healthcare and corporate clients in the defense of general litigation matters during the COVID-19 pandemic. 

For over a decade, she has represented a wide variety of clients in diverse areas of law, primarily involving complex litigation matters, including business disputes, contractual disputes, commercial and residential real estate, and construction matters. She has represented business owners, individuals, property owners, homeowners associations, non-profits, the hospitality industry, developers, general contractors, subcontractors and real estate brokerages and agents. She has also represented both healthcare and corporate clients in the defense of general litigation matters during the COVID-19 pandemic. 

This event will bring together other highly successful women in law to share their experiences, offer leadership insights, and provide practical career advancement strategies for legal professionals of any age.

If you’re looking to enhance your leadership presence and overcome self-doubt, this webinar could be a key turning point in your career.

Register for the Free Online Event and Step Into Your Power as a Woman in Corporate Law

Women’s History Month is a time to celebrate progress and invest in the next generation of female leaders.

The webinar will be moderated by Klinedinst Shareholder Grace Gower and will feature:

  • Natalie Vance – Klinedinst PC Shareholder
  • Hon. Randa M. Trapp (Ret’d.) – Former San Diego Superior Court Judge, Mediator at JAMS
  • Hon. Patricia D. Benke (Ret’d.) – Former Justice of the Fourth District Court of Appeal, Division One; Mediator at ADR Services and Of Counsel at Complex Appellate Litigation Group (CALG)

Click here to register.

About Klinedinst

Klinedinst is the go-to firm for clients looking for litigation, trial experience, transactional representation, and legal counsel. The firm’s offices in Irvine, Las Vegas, Los Angeles, Phoenix, Sacramento, San Diego, and Seattle service clients across the West, handling matters in California, Washington, Oregon, Nevada, and Arizona. What sets Klinedinst apart is the relationship our attorneys foster with each and every client. Klinedinst lawyers are indispensable strategic partners to business leaders, helping to achieve business objectives and create proactive solutions to resolve the many legal challenges that businesses are confronted with every day. Whether vigorously advocating for business clients in court, or guiding business transactions and negotiations, Klinedinst is the trusted legal advisor to have by your side.

Klinedinst PC announces that firm founder John D. Klinedinst has been reinstated as CEO, Shareholder Arthur S. Moreau, III has been elected President, and Shareholder Ian A. Rambarran elected Treasurer.

John D. Klinedinst, Esq.
John D. Klinedinst

SAN DIEGO, CA – Klinedinst PC is pleased to announce that John D. Klinedinst, our founding member, has returned to the position of CEO of the firm. Mr. Klinedinst will bring outstanding leadership and a client-centered culture built on high quality legal services that has served the firm well for over 40 years. Under his stewardship, Klinedinst will continue to promote its core values of open communication and opportunities for all.

Arthur S. Moreau, Esq.
Arthur S. Moreau, III

Additionally, Arthur S. Moreau, III, a longtime Shareholder in Klinedinst’s San Diego office, has been named President of the law firm. Mr. Moreau brings decades of experience as a Shareholder and a board member of Klinedinst PC. His vision for the law firm is to retain the firm’s core values while utilizing all the advantages of a modern law practice by leveraging advancements in technology, diversity, and the firm’s expanding regional footprint to provide the highest quality legal services to Klinedinst’s clients.

Ian. A. Rambarran

Finally, Shareholder Ian A. Rambarran has been elected Treasurer of the firm. Mr. Rambarran frequently counsels and represents clients in business and commercial disputes, representing lenders and financial institutions in disputes throughout California. As Treasurer, he will continue his work with the firm’s accounting team where he previously served in the role of assisting with collections.

“Klinedinst is well-positioned to meet the diverse legal needs of our clients now and in the future, thanks to John’s vision,” said Susan S. Nahama, COO and San Diego Managing Shareholder.

Klinedinst would also like to thank our former CEO, Heather Rosing, for her past work with the firm as she embarks on her new path.

About Klinedinst

Klinedinst is the go-to firm for clients looking for litigation, trial experience, transactional representation, and legal counsel. The firm’s offices in Irvine, Las Vegas, Los Angeles, Phoenix, Sacramento, San Diego, and Seattle service clients across the West, handling matters in California, Washington, Oregon, Nevada, and Arizona. What sets Klinedinst apart is the relationship our attorneys foster with each and every client. Klinedinst lawyers are indispensable strategic partners to business leaders, helping to achieve business objectives and create proactive solutions to resolve the many legal challenges that businesses are confronted with every day. Whether vigorously advocating for business clients in court, or guiding business transactions and negotiations, Klinedinst is the trusted legal advisor to have by your side.


IRVINE, CALIFORNIA – Fred M. Heiser, Managing Shareholder of Klinedinst’s Irvine office, has been elected to the Board of Directors of USLAW NETWORK. The membership elected the next year’s slate of directors during USLAW NETWORK’s Fall 2024 Client Conference in Vancouver, Canada. 

Frederick M. Heiser
Frederick M. Heiser

In his practice, Mr. Heiser works with clients of all sizes handling matters involving business and commercial litigation, commercial general liability, and employment litigation. In addition to litigation, Mr. Heiser partners with companies to strategically develop policies and procedures to minimize their liability risks. 

USLAW NETWORK is an association of approximately 100 independent, full-service firms, representing more than 6,000 attorneys across the U.S., Canada, Latin America, and Asia. Membership in USLAW is by invitation only, open to top-rated law firms that have substantial trial experience. With their regional and jurisdictional knowledge, USLAW member firms provide legal representation to major corporations, insurance companies, and large and small businesses. Matters handled by member firms include commercial and business law, employment and labor law, litigation, and other business-related areas of law.

Mr. Heiser has a long working relationship with USLAW NETWORK, as well as other member firms within the organization. Mr. Heiser was elected to the USLAW NETWORK’s Board of Directors for 2023-24, as well as serving previously in an ex officio role as the liaison between Future USLAW Leaders group and the board.

When not helping clients with their legal needs, Mr. Heiser is active in the community. In 2014, he was elected to serve on the Board of Directors for the Opera League of Los Angeles, becoming one of the youngest members to serve on the Board. He has been previously recognized as a Rising Star by Southern California Super Lawyers.® He is also a former President of Washington and Lee University’s Los Angeles Alumni Chapter, and remains an active member of the Chapter in Los Angeles and Orange County.

Klinedinst congratulates Mr. Heiser on his reelection to the Board of Directors for USLAW NETWORK. For more information on Mr. Heiser, please learn more at:

https://klinedinstlaw.com/profiles/attorney/frederick-heiser

About Klinedinst

Klinedinst is the go-to firm for clients looking for litigation, trial experience, transactional representation, and legal counsel. The firm’s offices in Irvine, Las Vegas, Los Angeles, Sacramento, San Diego, and Seattle service clients across the West, handling matters in California, Washington, Oregon, Nevada, and Arizona. What sets Klinedinst apart is the relationship our attorneys foster with each and every client. Klinedinst lawyers are indispensable strategic partners to business leaders, helping to achieve business objectives and create proactive solutions to resolve the many legal challenges that businesses are confronted with every day.  Whether vigorously advocating for business clients in court, or guiding business transactions and negotiations, Klinedinst is the trusted legal advisor to have by your side.

SAN DIEGO, CALIFORNIA –– Klinedinst PC is proud to announce that the firm has achieved the Mid-Size Mansfield Certification for 2023-2024. This marks the second year that the firm has been recognized by Diversity Lab, and recognized the work the firm has done to ensure equity and consistency in advancement across all seven offices.

The Mansfield Certification is named after Arabella Mansfield, who was the first female lawyer in the United States. Mansfield took the Iowa bar exam and scored high marks; however, the State of Iowa permitted only male candidates to sit for the bar exam. Mansfield challenged the males-only law in court and won her case, resulting in Iowa becoming the first state in the union to admit women and minorities to the practice of law in 1869.

In recognition of Ms. Mansfield’s achievement, the Mansfield Rule was created to help law firms identify ways to expand talent opportunities and increase diversity in leadership roles within the legal profession. Powered by Diversity Lab, the Mansfield Rule verifies that law firms have affirmatively considered women, lawyers of color, LGBTQ+ lawyers, and lawyers with disabilities for leadership and governance roles, equity partner promotions, formal client pitch opportunities, and senior lateral positions.

To achieve Mansfield Rule Certification, firms must undergo an independent multi-step program that measures the structural changes and tangible steps firms have taken to ensure paths to leadership – including lateral hiring, client pitch teams, promotions, appointments, and more – are open and transparent to all qualified lawyers. Mansfield’s processes are all designed to ensure equal opportunity and access to leadership roles.

The Mansfield Certification by Diversity Lab is a structured process backed by behavioral science. The entire process is designed to boost inclusivity, access, and diversity in leadership at every step. It encourages law firm management to make decisions in selecting future leaders by considering a broad pipeline of talent, including lawyers who are historically underrepresented in law. The same inclusive decision-making process is also encouraged when assembling client-centric service teams.

The Mansfield Rule program is designed to not exclude anyone, but instead expand the pool of lawyers to include additional qualified talent. According to Diversity Lab, recent studies, including the data analysis published in The American Lawyer and the New York State Bar Association Task Force on Advancing Diversity Report, praise Mansfield for its effective and lawful method for enhancing transparency and diversity in leadership.

“I am so impressed and proud of Klinedinst PC’s willingness and enthusiasm about Mansfield certification. The process is a huge commitment but our team has taken it on with passion and dedication to our core values,” said DEIB Committee Co-Chair Teresa Beck.

Klinedinst thanks Diversity Lab for building a collaborative platform for law firms to become Mansfield Certified, and looks forward to continuing its participation in the Mansfield Rule program for the 2024-2025 cycle. Learn more by downloading the official announcement from Diversity Lab. To learn more about Klinedinst’s efforts in improving diversity, please visit:

klinedinstlaw.com/diversity

About Klinedinst

Klinedinst PC is the go-to firm for clients looking for litigation and trial experience, sophisticated transactional advice, and other solution-oriented legal counsel. Providing legal services across the West, our attorneys are dedicated to fostering trusted relationships with each and every client, to help them achieve their individual goals and objectives. Klinedinst lawyers strive to serve as true business partners, always at the ready to address the legal challenges that business are confronted with every day. Whether in court, at the board meeting, or otherwise, KPC is the trusted legal advisor to have by your side.

IRVINE, CALIFORNIA — Klinedinst is honored to be recognized by the Orange County Coalition for Diversity in the Law (OCCDL) as a 2024 Top Legal Organization for DEI. The award, one of ten being given to local law firms, will be presented to Klinedinst at OCCDL’s Annual Awards Gala on October 3, 2024. The award honors organizations who have advanced diversity, equity, and inclusion in the Orange County legal community in the past year.

The Orange County Coalition for Diversity in the Law is the collaborative effort of professionals from leading Orange County law firms and other community partners promoting the recruitment, retainment, equity among, and advancement of diverse attorneys in Orange County. The OCCDL provides practical workshops, diversity-based education (CLEs), and supports local Orange County law school and high school students from underrepresented communities.

“We are thrilled to be recognized for our ongoing commitment to supporting diversity within the legal profession, the firm, and the Orange County office,” said Klinedinst’s Chief Diversity Officer Natalie Vance.

The firm’s commitment to diversity and equity goes back two decades, when the firm was an original signatory to the Los Angeles County Bar Association’s 2005 Statement of Diversity Goals and Principles. Klinedinst has since received numerous recognitions for DEIB initiatives, including the Corporate Commitment Diversity Award from the Earl B. Gilliam Bar Association and, most recently, the State Bar of Nevada’s 2024 Partner in Diversity Medallion. The firm has also achieved Mid-size Mansfield Rule Certification for 2022-2023. Powered by Diversity Lab, Mansfield Rule Certification verifies that law firms have affirmatively considered women, lawyers of color, LGBTQ+ lawyers, and lawyers with disabilities for leadership and governance roles, equity partner promotions, formal client pitch opportunities, and senior lateral positions. This year, the firm was also named a Best Company to Work For: Law Firm for 2024 by U.S. News & World Report.

Klinedinst thanks the Orange County Coalition for Diversity in the Law for this recognition and for their commitment to elevating DEIB in the legal community.

Learn more about Klinedinst’s unwavering commitment to diversity at www.klinedinstlaw.com/about/diversity

About Klinedinst

Klinedinst PC is the go-to firm for clients looking for litigation and trial experience, sophisticated transactional advice, and other solution-oriented legal counsel. Providing legal services across the West, our attorneys are dedicated to fostering trusted relationships with each and every client, to help them achieve their individual goals and objectives. Klinedinst lawyers strive to serve as true business partners, always at the ready to address the legal challenges that businesses are confronted with every day. Whether in court, at the board meeting, or otherwise, KPC is the trusted legal advisor to have by your side.


SAN DIEGO, CALIFORNIA – Klinedinst announces that six attorneys have been selected for inclusion in The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America.

Published annually, Best Lawyers recognizes top-caliber attorneys in over 150 practice areas. For the 2025 edition of The Best Lawyers in America, the organization received 27 million evaluations from lawyers to determine the most talented and esteemed professionals in the industry. This included a record-shattering 4.2 million responses from this year alone. Best Lawyers uses the input of these attorneys to then decide this year’s honorees.

In 2025, Best Lawyers recognized more than 80,000 lawyers, a 5% increase over the previous year. Klinedinst lawyers who are recognized in the 2025 edition of Best Lawyers include:

Being recognized by Best Lawyers is a testament to exceptional practice. Klinedinst congratulates these outstanding lawyers for being recognized in the 2025 edition of Best Lawyers. To learn more about each, please visit:

www.klinedinstlaw.com/best-lawyers

About Klinedinst

Klinedinst PC is the go-to firm for clients looking for litigation and trial experience, sophisticated transactional advice, and other solution-oriented legal counsel. Providing legal services across the West, our attorneys are dedicated to fostering trusted relationships with each and every client, to help them achieve their individual goals and objectives. Klinedinst lawyers strive to serve as true business partners, always at the ready to address the legal challenges that businesses are confronted with every day. Whether in court, at the board meeting, or otherwise, KPC is the trusted legal advisor to have by your side.

SAN DIEGO, CALIFORNIA – Klinedinst was pleased to host a special DEIB webinar featuring John Miller, Staff Attorney with Lambda Legal. The webinar, which took place on August 13, 2024, was moderated by Shareholder Brian P. Murphy.

Mr. Miller, who is based in Los Angeles and also serves as an adjunct professor at the University of Southern California’s Gould School of Law, discussed the past, present, and future of Lambda Legal’s work representing the LGBTQ+ community. Mr. Miller and his team serve as the first line of defense when it comes to the legal department, fielding 5,000 calls every year from people facing discrimination.

Lambda Legal is the oldest and largest national legal organization whose mission is to achieve full recognition of the civil rights of lesbians, gay men, bisexuals, transgender people and everyone living with HIV. Lambda attorneys have been behind many of the court cases that have secured the rights of LGBTQ+ individuals, including the landmark Obergefell decision that recognized marriage equality.

“Lambda Legal does vitally important work that is close to my heart,” said Mr. Murphy, who is based in Klinedinst’s San Diego law office. “This webinar gives viewers a chance to go behind-the-scenes with an organization that is on the frontlines in the fight for LGBTQ+ equality.”

During the webinar, Mr. Miller reviewed important milestones in the history of the LGBTQ+ movement, from founding through present day. He also discussed pending legal cases, and what the future may hold for cases that are working their way through the U.S. court system.

Klinedinst thanks Mr. Miller and Lambda Legal for participating in this special event. To learn more about Lambda Legal, please visit: klinedinstlaw.com/lambda-legal

About Klinedinst 

Klinedinst PC is the go-to firm for clients looking for litigation and trial experience, sophisticated transactional advice, and other solution-oriented legal counsel. Providing legal services across the West, our attorneys are dedicated to fostering trusted relationships with each and every client, to help them achieve their individual goals and objectives. Klinedinst lawyers strive to serve as true business partners, always at the ready to address the legal challenges that businesses are confronted with every day. Whether in court, at the board meeting, or otherwise, KPC is the trusted legal advisor to have by your side.

IRVINE, CALIFORNIA – Klinedinst PC has just posted an opening for an organized and professional Legal Operations Manager to join our vibrant and collaborative team. The ideal Legal Operations Manager candidate would be based in our Irvine location and oversee the operations of both our Irvine and Los Angeles offices.

Klinedinst is dedicated to providing top-caliber legal services to clients across the West, while nurturing the professional development and personal advancement of each and every employee. We work hard to promote a positive, energizing culture built on teamwork and inclusion. It’s the reason why Klinedinst has been named a Best Place to Work: Law Firm by US News & World Report in 2024.

As Legal Operations Manager, we want you to inspire and help lead these teams to success.

Learn More

About Klinedinst

Klinedinst PC is the go-to firm for clients looking for litigation and trial experience, sophisticated transactional advice, and other solution-oriented legal counsel. Providing legal services across the West, our attorneys are dedicated to fostering trusted relationships with each and every client, to help them achieve their individual goals and objectives. Klinedinst lawyers strive to serve as true business partners, always at the ready to address the legal challenges that businesses are confronted with every day. Whether in court, at the board meeting, or otherwise, KPC is the trusted legal advisor to have by your side.