CTA Individual U.S. Person Data to Be Deleted

The U.S. Financial Crimes Enforcement Network (FinCEN) issued a final rule on August 11, 2026. The final rule removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act (CTA).

FinCEN also announced it will delete previously reported information about individual U.S. persons from the BOI database.

CTA Limited to Foreign Reporting Companies

The new definition of “reporting company” includes only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. state or tribal jurisdiction by the filing of a document with a secretary of state or similar office.

Entities which were previously defined as “domestic reporting companies” are now exempt from BOI reporting requirements. This means that an entity which was formed in the U.S. (e.g., Delaware LLC, New York corporation) and the entity’s beneficial owners (BOs) will be exempt from the requirement to report BOI to FinCEN.

Entities that meet the new definition of a “reporting company” are not required to report any U.S. persons as BOs or any U.S. person “company applicants” (i.e., the individuals who helped those foreign companies register to do business in the U.S.).

Previously Submitted Data

Entities that are not “foreign reporting companies” which previously submitted a Beneficial Ownership Information Report (BOIR) are not required to file updates or corrections to the previously submitted BOIR. Likewise, U.S. persons who previously obtained a FinCEN ID no longer have any obligation to update or correct the information they originally provided to FinCEN to obtain their FinCEN IDs. Foreign pooled investment vehicles registered in the U.S. are also exempt from reporting a U.S person in control of the investment vehicle as a BO.

FinCEN will delete information in its BOI database about individuals who were reported as company applicants, BOs, or recipients of a FinCEN ID. FinCEN will base its decision to delete the information on FinCEN’s reasonable belief that the individual is a U.S. person by, for example, determining if the information is linked to a U.S. passport or U.S. driver’s license.

Click to read FinCEN CTA Final Rule. The final rule will become effective upon publication in the Federal Register this month.

Click to read FinCEN’s Final Rule Questions and Answers document.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.