
If your U.S. company previously filed ownership information under the Corporate Transparency Act (CTA), if your personal information was included in a filing, or if you are a foreign company registered to do business in the United States, there are important changes you should know about. On August 11, 2026, the Financial Crimes Enforcement Network (FinCEN) finalized a rule that permanently narrows who must report under the CTA. The rule took effect on August 14, 2026. FinCEN also announced plans to delete certain previously reported information about U.S. companies and U.S. individuals from its database.
Congress passed the CTA in 2021 to help law enforcement fight money laundering, terrorism financing, tax fraud, and other financial crimes. Under the original rules, millions of U.S. corporations, LLCs, and similar entities, along with certain foreign entities registered to do business in the United States, were required to report information about their owners to FinCEN.
That changed significantly in March 2025. After legal challenges to the CTA, a change in presidential administrations, and a reassessment of the burden on U.S. businesses, FinCEN issued a temporary rule that removed the reporting requirement for U.S.-formed companies and eliminated the need for foreign companies to report information about their U.S.-person owners.
The August 2026 final rule makes those changes permanent and goes further to protect U.S. individuals. Here is what it means in practice: U.S.-formed companies no longer need to file ownership reports with FinCEN. Companies that do still file are not required to include information about U.S.-person owners or the individuals who filed the company’s formation documents (known as “company applicants”). U.S. individuals are not required to provide that information. And U.S. individuals who previously obtained a FinCEN identifier, a unique number FinCEN assigns to individuals who register directly, no longer need to keep that information up to date.
Foreign companies, meaning companies formed under another country’s laws that are registered to do business in the United States, are still required to report. If you are a foreign company, you should determine whether you qualify as a “reporting company” under the CTA and, if so, identify what information about your non-U.S. owners you still need to file. You do not need to include information about U.S.-person owners or company applicants.
FinCEN describes the final rule as a shift from collecting ownership information as broadly as possible to a more targeted approach focused on where the risks are greatest. While the CTA is designed to give law enforcement useful information, it also requires the government to keep the burden on businesses as low as possible.
The government concluded that requiring millions of mostly law-abiding U.S. small businesses to file ownership reports created costs that outweighed the benefits. Narrowing the rules does mean less information will be available for investigations into shell companies, money laundering, sanctions violations, and fraud. But the government determined that focusing on foreign entities registered in the United States strikes a better balance — it concentrates reporting where the risk is highest and the compliance burden is most justified.
For businesses and individuals who already filed under the original rules, the most important news may be what FinCEN plans to do with the information it has already collected.
Millions of U.S. companies submitted ownership information under the original rules. Many commenters asked FinCEN to delete information that would no longer need to be reported, pointing to concerns about privacy, cybersecurity, and potential misuse of the data. FinCEN agreed and said it would remove “as much as practicable” of the information that would not have been collected if today’s narrower rules had been in place from the start.
FinCEN plans to carry out a one-time deletion, not an ongoing process. It will review previously filed reports to identify U.S. companies and their reported owners and company applicants. It also plans to work with the National Archives and Records Administration to delete information about individuals where the identification document on file (such as a U.S. passport or driver’s license) suggests the person is a U.S. citizen or resident.
FinCEN does not expect to require companies or individuals to submit a request to have their information deleted, and it does not plan to send individual confirmations. Instead, it expects to post a notice on its website once the deletion process is finished.
There is an important deadline to keep in mind: if information about a U.S. company or U.S. person is included in a filing made after February 10, 2027, whether intentionally or by mistake, FinCEN will not delete it as part of this process.
If your U.S. company previously filed ownership information with FinCEN, or if your personal information was included in a filing, you do not need to take any immediate action. However, you should know that FinCEN plans to delete that data on its own. If you are a foreign company registered to do business in the United States, you should review whether you are still required to report and, if so, what information you need to file now that U.S.-person information is excluded. In all cases, it is worth keeping an eye on FinCEN’s website for updates on the deletion process and any additional guidance.
If you have any questions about how these changes may affect you or your business, please do not hesitate to reach out to Juan Arau.
Patrick Ross, Senior Manager of Marketing & Communications
EmailP: 619.906.5740
Suzie Jayyusi, Senior Marketing Coordinator Events Planner
EmailP: 619.525.3818
Francisco Sanchez Losada, Marketing and Client Relations Manager
EmailP: 619.515.3225
Sanae Trotter, Senior Manager for Client Relations
EmailP: 650.645.9015