FinCEN Issues BOI Final Rule
On August 11th, FinCEN issued a Final Rule that permanently ended the requirements for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN. Foreign entities that are considered “reporting companies” will still be required to report BOI for foreign individuals, however. The Final Rule took effect on August 14, 2026.
You may recall that the BOI requirements originally came about as part of the Corporate Transparency Act and took effect on January 1, 2024; however, litigation ensued which led to delays and FinCEN ultimately issued an interim final rule that narrowed the coverage of the BOI and which this recent Final Rule solidifies. Keep in mind, this Final Rule impacts U.S. companies and U.S. persons and has no effect on the beneficial ownership requirements financial institutions must follow. We wanted to bring awareness to this development as it will likely impact financial institution customers. Frequently Asked Questions were also issued to assist affected parties.
One fairly recent change that DID impact the beneficial owner requirements for financial institutions was FinCEN’s Order granting “exceptive relief” in certain circumstances. To learn more, check out our webinar, “Exceptive Relief for Beneficial Owner Due Diligence”, which is available now OnDemand.
Published 2026/08/18
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!