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