As of April 2026, U.S. domestic companies remain exempt from mandatory beneficial ownership information (BOI) reporting to FinCEN under the Corporate Transparency Act (CTA), following the Trump administration’s March 2025 interim final rule restricting reporting obligations to foreign entities registered to do business in the United States. The policy rollback — which effectively suspended BOI requirements for an estimated 99.8% of covered entities — continues to generate significant concern among AML practitioners and transparency advocates.
The exemption for domestic reporting companies means that the U.S. — which has long been criticised for providing anonymous corporate structures attractive to money launderers, sanctions evaders, and corrupt actors — has materially weakened one of the most significant anti-money laundering reforms in a generation. The FACT Coalition noted that anonymous shell companies remain ‘a favourite tool of global adversaries and criminals including fentanyl traffickers, money launderers, and tax cheats.’
For financial institutions, the practical compliance implication is unchanged in the short term: CDD rules still require banks to independently collect and verify beneficial ownership information from legal entity customers at account opening, and FinCEN’s CDD rule remains in force. The removal of FinCEN’s central beneficial ownership registry, however, reduces the quality of cross-institutional intelligence available to support SAR investigations and law enforcement referrals.
Financial institutions serving complex corporate structures should review their CDD procedures to ensure they are not relying on the now-defunct expectation of FinCEN BOI filings to substitute for independent ownership verification. Enhanced scrutiny of multi-layered domestic corporate customers — particularly those with opaque ownership chains, nominee arrangements, or structures inconsistent with declared business purposes — remains a critical control in the absence of a functioning public registry.
By FCCT Editorial Team
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