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ARTICLE · 01 SEPTEMBER 2026

FinCEN Finalizes Changes To The Corporate Transparency Act

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The Treasury Department has issued a final rule permanently limiting the Corporate Transparency Act's enforcement to foreign entities only, exempting domestic U.S. companies from beneficial ownership reporting requirements. However, this significant narrowing faces potential legal challenges and could be reversed by future administrations, leaving the ultimate fate of the CTA uncertain.

United StatesGovernment, Public Sector
Douglas M. Weissinger
Douglas M. Weissinger
Randall D. McClanahan
Randall D. McClanahan
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We previously wrote about the Treasury Department and FinCEN’s issuance of an interim rule declining to enforce penalties or fines against U.S. citizens or domestic reporting companies, effectively limiting the scope of the Corporate Transparency Act (“CTA”) to foreign reporting companies only. That article can be found here.

On August 11, 2026, the Treasury Department issued a final rule to make those changes permanent, along with updated FAQs. Treasury also stated that it will delete previously reported information relating to domestic individuals and entities from the Beneficial Ownership Information (“BOI”) database. Foreign entities, however, remain subject to the BOI reporting requirements.

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