UBO Data for the US: Corporate Transparency Act and FinCEN

The US Corporate Transparency Act (CTA) was originally designed to require most US companies to report beneficial ownership information (BOI) to FinCEN. That scope has since narrowed significantly, and it's still evolving. For compliance teams, understanding the current federal reporting status — and why UBO data remains necessary regardless of it — matters more than ever.

Current Status of Federal BOI Reporting

In March 2025, FinCEN published an interim final rule that substantially narrowed who has to report. Under the revised rule, the definition of "reporting company" now covers only entities formed under the law of a foreign country that have registered to do business in a US state or tribal jurisdiction — what was formerly called a "foreign reporting company." Entities formed in the United States, and their beneficial owners, are no longer required to report BOI to FinCEN. Foreign reporting companies also no longer have to report BOI for beneficial owners who are US persons.

Companies that were already registered to do business in the US before March 26, 2025 had an initial BOI report due by April 25, 2025. Foreign reporting companies registering on or after that date must file within 30 calendar days of receiving notice that their registration is effective.

A final rule addressing the CTA's BOI reporting requirements was submitted for regulatory review in June 2026 and had not been finalized as of this writing. Compliance teams should treat federal BOI reporting scope as subject to further change and confirm current requirements directly with FinCEN before making filing determinations.

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Why UBO Data Still Matters Regardless of CTA Scope

The narrowing of federal BOI reporting requirements does not eliminate the need for beneficial ownership data in US compliance programs. Several obligations sit outside the CTA entirely:

US financial institutions have separate, longstanding obligations under the BSA's customer due diligence rule to identify beneficial owners of legal entity customers at account opening — an obligation that exists independent of CTA reporting requirements.

Some states and regulated sectors maintain their own beneficial ownership disclosure or verification expectations that aren't tied to federal CTA filings.

Regardless of what's formally reportable to FinCEN, institutions still need to know who ultimately controls a counterparty to manage sanctions exposure and AML risk effectively.

Foreign entities registered to do business in the US still have active BOI reporting obligations under the current rule, and compliance teams working with foreign-owned US-registered entities need reliable ownership data to support that.

With a final rule pending review as of mid-2026, compliance programs that dismantled beneficial ownership data processes entirely around the narrowed CTA scope may need to rebuild them quickly if the rule shifts again.

What US Compliance Teams Should Do

Frequently Asked Questions

Do US-formed companies still have to report beneficial ownership to FinCEN?

As of the March 2025 interim final rule, US-formed entities and their beneficial owners are no longer required to report BOI to FinCEN. Only foreign entities registered to do business in the US remain in scope.

Is this rule final?

No. A final rule on the CTA's BOI reporting requirements was submitted for regulatory review in June 2026 and had not been finalized as of this writing. Requirements should be confirmed directly with FinCEN before making compliance decisions.

If CTA reporting doesn't apply to my company, do I still need UBO data?

Often yes. Financial institutions still need beneficial ownership data for Bank Secrecy Act customer due diligence, and many compliance programs use UBO data for AML and sanctions screening independent of CTA reporting obligations.

Does this affect UBO data requirements outside the US?

No. The CTA scope change is specific to US federal reporting to FinCEN and doesn't affect beneficial ownership disclosure requirements in other jurisdictions.

UBO Data from Techsalerator

Techsalerator provides licensed, continuously monitored UBO data covering US and foreign-registered entities as part of its coverage across 195 countries, built to support AML, sanctions screening, and due-diligence programs regardless of shifting reporting requirements.

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