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Corporate Transparency Act Reporting Deadline: December 31

Client Alert

The Corporate Transparency Act (“CTA”), which became effective January 1, 2024, imposes strict reporting guidelines on small business owners throughout the country. The deadline for non-exempt businesses to submit reporting is December 31, 2024.

The civil penalty for failing to file reporting required under the CTA if $591 per day, up to a total of $10,000. Also note that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information or (ii) fails to report and/or update a report previously made.

If you are the beneficial owner of an entity formed pursuant to a filing with a state secretary of state’s office (i.e., an LLC or a corporation), your entity must report. There are a few exemptions to this reporting requirement. If an entity meets an exemption, it does not need to presently report.  However, if an exemption ever becomes inapplicable to the entity, the entity then has 30 days to report. 

Completed reports are not public record; reporting is maintained by the financial crimes wing of the Department of the Treasury in a database that’s only accessible by state and federal law enforcement.

To avoid facing a potential steep fine to kick of your 2025 fiscal year, or to better understand whether your entity needs to report, please do not hesitate to contact BMD Attorney Jacob R. Davis (jrdavis@bmdllc.com).

For a more detailed overview on the CTA, click here.


Name, Image, and Likeness Agreements in Healthcare

For example, some healthcare providers have begun to utilize "Name, Image, and Likeness" agreements to promote the brand they have created through their healthcare practice.  We have seen the most healthcare NIL activity with longevity and wellness providers, as well as orthopedics.

Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.

Top Compliance Risks for Ohio Med-Spas in 2025

The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.

Pre and Postnuptial Agreements | Necessary, Maybe, What Happened to Forever?

Both Florida and Ohio now allow clients to enter into a prenuptial or postnuptial agreement prior to marriage or after marriage (Ohio previously did not allow postnuptial agreements). Both documents have statutory guidelines that must be followed in terms of execution and financial disclosure.

DHS Ends All Employment Authorization Auto-Extensions

Effective October 30, 2025, DHS ends all automatic work authorization renewals. The 540-day extension applies only to renewals filed before this date, and there is no grace period for expired EADs filed on or after October 30. Employers must audit EADs, train staff, ensure I-9 compliance, and plan for work authorization gaps. Penalties for noncompliance can be severe.