In December 2024, Winston’s CTA Task Force attorneys began covering a series of judicial actions that affected the enforcement status of the Corporate Transparency Act and its beneficial ownership information reporting rule.
On December 23, 2023, New York Governor Kathy Hochul signed the LLC Transparency Act into law, with a chapter amendment to be approved by the New York State Legislature. The chapter amendment was later approved, and on March 1, 2024, Governor Hochul signed the amended LLC Transparency Act (the Act) into law. The Act takes effect on January 1, 2026 and requires all limited liability companies formed in New York State or qualified to do business in New York State to file a beneficial ownership disclosure or attestation of exemption with the New York Department of State.

As federal antitrust enforcement continues to evolve, adjust priorities, and in some cases, stall out, states are increasingly enhancing their enforcement focus, resources, and law.