Rudo Mugwagwa
Rudo advises on investment funds, corporate, and cross-border compliance matters, with experience across fund formation, governance, and investor-side advisory.
The Financial Crimes Enforcement Network (“FinCEN”) published the final rule exempting entities formed under the laws of any State or Tribal jurisdiction of the U.S. (“U.S. Entities”) and U.S. persons from the obligation to report beneficial ownership information (“BOI”) to FinCEN under the Corporate Transparency Act effective as of August 14, 2026.
For U.S. Entities and U.S. persons this means the following, as applicable:
- U.S. Entities are exempt from filing any BOI reports.
- Non-exempt foreign entities registered to do business in the U.S. (“Reporting Companies”) do not need to report BOI for U.S. persons that are beneficial owners or U.S. person company applicants.
- U.S. persons do not need to provide any BOI to Reporting Companies.
- FinCEN expects to delete BOI previously reported by or for U.S. persons from the BOI database.
- U.S. persons who obtained FinCEN identifiers are not required to update or correct the information provided in their applications.
Reporting Companies will still be required to report BOI for non-U.S. persons including where are all beneficial owners are U.S. persons.