FinCEN ends Beneficial Ownership Information requirement for US companies and US persons

FinCEN issued a final rule that permanently adopts the beneficial ownership information reporting framework established under the interim final rule of March 2025, thereby confirming on a permanent basis that domestic reporting companies and United States persons remain exempt from beneficial ownership reporting obligations under the Corporate Transparency Act, while foreign reporting companies continue to be required to report beneficial ownership information solely with respect to their non-United States beneficial owners. The final rule further expands upon the interim rule by extending the exemption previously applicable only to United States person beneficial owners to now also encompass United States person company applicants, who had remained subject to reporting obligations under the interim final rule, and by eliminating the requirement for United States persons holding a FinCEN identifier to update or correct previously submitted identifying information. In addition, FinCEN confirmed that it intends to conduct a single, one-time deletion of beneficial ownership information previously reported by United States persons to identify and remove records associated with identifying documents reasonably believed to have been issued by a United States authority, such as a passport or driver's license; however, this deletion process will not extend to any beneficial ownership information submitted after the expiration of the 180-day period following publication of the rule, and FinCEN has indicated that it will not provide confirmation of deletion to individual filers upon request.