What changed
- A March 2025 FinCEN interim final rule exempted US companies and US persons from Corporate Transparency Act BOI reporting.
- Only certain foreign entities registered to do business in the US still have to report.
- Financial institutions' own customer due diligence and beneficial-ownership obligations remain in place.
Who's affected
Banks, fintechs, trust and corporate service providers, law firms, and anyone onboarding US entities.
What compliance teams should do now
- Do not assume a government registry has vetted the owners of a US LLC — research them yourself.
- Screen every identified beneficial owner and controller, not just the entity name.
- Escalate opaque, multi-layer structures for enhanced due diligence.
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How AMLX helps
AMLX lets you screen each owner, director, and controller behind an entity against sanctions, PEP, adverse media, and court records — and keep the record.
Built for: Banks & Credit Unions · Law Firms & Advisors · Real Estate & Title Companies · Trust & Corporate Service Providers
Jurisdiction coverage: United States screening · Cayman Islands screening · British Virgin Islands screening
Related regulatory updates
- FinCEN's 2026 AML/CFT Program Rule Overhaul — FinCEN has proposed a fundamental, risk-based reform of AML/CFT program requirements for every BSA-covered financial institution.
- Investment Adviser AML Rule Delayed to 2028 — FinCEN pushed its investment adviser AML/CFT rule from January 1, 2026 to January 1, 2028 — but the delay is a runway, not an exemption.
- FinCEN Residential Real Estate Rule Vacated — The FinCEN Residential Real Estate Rule took effect March 1, 2026 and was vacated by a federal court in Texas on March 19, 2026. Laundering risk in all-cash deals did not go anywhere.
Frequently asked questions
What is the beneficial ownership screening after CTA change?
US companies no longer file BOI reports with FinCEN — so beneficial-ownership diligence falls back on you.
Who does this affect?
Banks, fintechs, trust and corporate service providers, law firms, and anyone onboarding US entities.
How can AMLX help us respond?
AMLX lets you screen each owner, director, and controller behind an entity against sanctions, PEP, adverse media, and court records — and keep the record. You can start on the free tier with no sales call.
Sources
This page summarises public regulatory developments for general information. It is not legal advice; confirm current status with the regulator or your counsel.