First announced: FinCEN issued an interim final rule in March 2025 and a further final rule on August 11, 2026.
Submitted by: NYBACS Compliance Desk
What changed
The federal beneficial ownership information reporting framework has changed. FinCEN’s current guidance states that U.S.-created entities and U.S. persons are exempt, while certain entities formed under foreign law and registered to do business in the United States may remain subject to reporting.
Who’s affected
U.S.-formed companies, foreign companies registered in the United States, their owners, and businesses that assist with federal compliance filings.
Immediate actions
- Determine where the entity was formed and whether it registered in the United States.
- Review the current FinCEN rule, exemptions, and deadlines.
- Keep ownership records available for banks, tax filings, and state requirements.
- Recheck FinCEN guidance before deciding whether a filing is required.
Practical note & timeline
Federal CTA reporting is separate from state filings, tax obligations, and bank due diligence. FinCEN’s rules have changed; verify the current requirements before acting.
Source: https://www.fincen.gov/boi
