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ReadToday, August 11, 2026, FinCEN issued a final rule that permanently removes beneficial ownership reporting for US companies and US persons under the Corporate Transparency Act. FinCEN is the Financial Crimes Enforcement Network, the bureau of the US Treasury that collects financial intelligence to fight money laundering. The rule takes effect when it is published in the Federal Register, the official journal of the US government, which the Treasury has scheduled for August 14, 2026.
Treasury Secretary Scott Bessent called it "a victory for common sense and American small businesses."
Where this leaves things
In March 2025, FinCEN issued an interim rule that exempted every company formed in the United States from reporting its owners, and limited reporting to companies formed abroad that register to do business in a US state. We covered that rule and the court battles that led to it in our earlier article on the interim rule.
An interim rule takes effect immediately but stays open to comment and can be changed. FinCEN had said it hoped to finalise it in 2025. Today's rule does that, adopting the March 2025 exemptions as permanent and adding several further changes.
What the final rule does
- US companies are permanently exempt. No entity formed in the United States has to file, update or correct a beneficial ownership report with FinCEN.
- FinCEN identifiers. US persons who obtained a FinCEN identifier, a number individuals could use instead of resubmitting their details for each company, no longer have to keep that information up to date.
- Company applicants. Foreign companies no longer have to report the US persons who helped them register to do business in the United States, known as company applicants.
- Investment funds. Foreign pooled investment vehicles registered in the United States no longer have to report a US person who controls them.
- Foreign reporting companies still file. Companies formed under foreign law and registered in a US state must still report their foreign beneficial owners.
What gets deleted
The most notable change is that FinCEN will delete information it already holds. It will remove data on any individual it reasonably believes is a US person, for example information linked to a US passport or a US driver's licence. That covers beneficial owners, company applicants and holders of FinCEN identifiers.
For non US founders, the detail matters. The announcement describes the deletion in terms of US persons. It does not say that information about non US individuals, including owners of US LLCs who filed reports in 2024 before the exemption, will be removed. Their US companies have no further reporting obligation, but they should not assume that what was filed has been erased.
What does not change
The rule concerns only FinCEN's beneficial ownership database. Banks and payment providers still ask who owns a business when opening and reviewing accounts, under separate customer due diligence rules. US tax filings that apply to foreign owned LLCs, and state level formation and annual filings, continue as before. A foreign company that registers in a US state, such as a BVI holding company with a US registration, still has to report its foreign owners to FinCEN.
What it means for our clients
For clients holding a US LLC, whether they live in the United States or abroad, today's rule settles the question that has hung over US companies since 2024. There is no beneficial ownership report to file with FinCEN, now or in future, unless the rules change again through a new rulemaking or an act of Congress.
Clients using a company formed outside the United States, such as a BVI, Nevis, UAE or Hong Kong company, that registers to do business in a US state should keep treating it as a reporting company and keep its filing current. We help clients set up and maintain company structures with our local teams, and can review whether a given structure triggers any US reporting.
This article is general information, not legal, tax or investment advice.
