The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Thu, 27 Aug 2026 15:43:45 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.10 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png FinCEN Permanently Eliminates BOI Reporting Requirements for US Companies and US Persons – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 FinCEN Permanently Eliminates BOI Reporting Requirements for US Companies and US Persons https://corpgov.law.harvard.edu/2026/08/27/fincen-permanently-eliminates-boi-reporting-requirements-for-us-companies-and-us-persons/?utm_source=rss&utm_medium=rss&utm_campaign=fincen-permanently-eliminates-boi-reporting-requirements-for-us-companies-and-us-persons https://corpgov.law.harvard.edu/2026/08/27/fincen-permanently-eliminates-boi-reporting-requirements-for-us-companies-and-us-persons/#respond Thu, 27 Aug 2026 11:30:44 +0000 https://corpgov.law.harvard.edu/?p=183564?d=20260827114345EDT Posted by Matthew Bisanz, Brad A. Resnikoff, and Marcella Barganz, Mayer Brown LLP, on Thursday, August 27, 2026
Editor's Note:

Matthew Bisanz and Brad A. Resnikoff are Partners and Marcella Barganz is a Counsel at Mayer Brown LLP. This post is based on a Mayer Brown memorandum by Mr. Bisanz, Mr. Resnikoff, Ms. Barganz, Lorenz A. Taets, and Kelly F. Truesdale, all at Mayer Brown LLP.

On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that permanently removes the requirement for US companies and US persons to report beneficial ownership information (“BOI”) to FinCEN under the Corporate Transparency Act (the “CTA”). The Final Rule was published in the Federal Register on August 14, 2026, and became effective immediately upon publication.

The Final Rule adopts all of the changes made on an interim basis in the interim final rule issued on March 26, 2025 (the “IFR”) as permanent changes. As discussed in our prior Legal Update, such changes narrowed FinCEN’s beneficial ownership information reporting requirements to apply only to foreign entities registered to do business in the United States. Specifically, the Final Rule confirms the elimination of reporting obligations for millions of US small businesses, resolves open questions flagged in our prior Legal Updates regarding FinCEN identifiers and company applicants, and announces the planned deletion of previously reported US person data from FinCEN’s BOI IT system (the “BOI IT System”). The Secretary of the Treasury’s issuance of the Final Rule cements its exercise of statutory exemptive authority under the CTA and the Bank Secrecy Act more generally.

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