On August 11, 2026, the Financial Crimes Enforcement Network (FinCEN) finalized a rule that exempts U.S. companies and U.S. persons from the federal Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA).

For Money Services Businesses (MSBs), there is an important distinction to understand;  this new rule does not change any AML compliance obligations.

What Changed?

The new FinCEN rule changes who must report beneficial ownership information to the federal government.

Under the final rule:

• U.S. companies are exempt from BOI reporting.
• U.S. persons do not have to provide BOI to reporting companies.
• Reporting companies generally do not have to report U.S. persons as beneficial owners or company applicants.
• Certain foreign entities that meet the definition of a reporting company remain subject to BOI reporting requirements.

The change effectively separates federal ownership reporting from the broader compliance responsibilities of financial institutions.

An MSB should not interpret the end of a CTA filing requirement as permission to stop asking questions about ownership, control, customers, or the source and purpose of transactions.

The Important Distinction for MSBs

The Corporate Transparency Act (CTA) and the Bank Secrecy Act (BSA) serve related but different purposes.

The CTA created a federal reporting mechanism designed to provide the government with beneficial ownership information about certain companies.

The BSA, on the other hand, establishes requirements designed to prevent financial institutions from being used for money laundering, terrorist financing and other financial crimes.

FinCEN continues to identify MSBs as businesses subject to BSA requirements, including the requirement to establish and maintain a written anti-money laundering / countering the financing of terrorism (AML/CFT) program. That program must be risk-based and include policies, procedures and internal controls reasonably designed to assure compliance with the BSA and its implementing regulations.

Reporting Relief Does Not Equal AML Relief

Beneficial ownership information can be an important component of an MSB’s customer due diligence and risk assessment processes.

Know your customer (KYC) and customer identification program (CIP) controls can help an MSB understand who is actually behind a customer relationship, identify higher-risk relationships, recognize unusual activity and investigate transactions that may warrant additional attention.

FinCEN has long recognized that beneficial ownership information can help financial institutions identify and address money laundering and terrorist financing risks. Its guidance explains that customer due diligence (CDD) should be commensurate with an institution’s BSA/AML/CFT risk, with enhanced attention to higher-risk customers.

An MSB may no longer need to collect information to satisfy a CTA filing requirement, but ownership and control information continues to be necessary to understand its customer and manage the risks associated with that relationship.

What Should MSBs Do Now?

This regulatory change is a good reason for MSBs to review their beneficial ownership procedures.

MSBs should consider whether their current policies and procedures clearly distinguish between:

Information required to be reported to FinCEN under the CTA

vs

Information the MSB needs to obtain and maintain as part of its own AML/CFT program.

That review may lead to changes in forms, onboarding procedures or documentation, but those changes should be based on the MSB’s risk assessment and regulatory obligations.

An MSB should consider:

• Whether its customer onboarding process obtains sufficient information to understand the nature and purpose of the customer relationship.
• Whether ownership and control information is necessary to appropriately assess customer risk.
• Whether higher-risk customers warrant additional ownership, control or other identifying information.
• Whether existing policies require information that was collected solely to satisfy the former CTA reporting framework.
• Whether employees understand the difference between BOI reporting and AML CDD.
• Whether changes to onboarding procedures could affect the MSB’s ability to identify and investigate suspicious activity.

The Bottom Line for MSBs

FinCEN’s new rule provides meaningful regulatory relief for many U.S. businesses by eliminating the federal BOI reporting obligation, but MSBs operate in a different regulatory environment.

FinCEN continues to require MSBs to maintain AML/CFT programs designed to comply with the BSA, and suspicious activity reporting, recordkeeping and other BSA obligations remain in place.

As regulatory requirements continue to evolve, MSBs should focus less on whether a particular form or filing has disappeared and more on whether their overall compliance program still provides the information, controls and oversight necessary to identify and mitigate financial crime risk.

If you are unsure of your reporting obligations, would like to evaluate your risk, or would like to talk to a compliance expert, contact us today. 

Tags: AML/CFT Program, Anti Money Laundering, Bank Secrecy Act, BSA, CDD, CIP, CTR, Currency Transaction Report, Customer Due Diligence, Customer Information Program, Financial Crimes Enforcement Network, FinCEN, Know Your Customer, KYC, Risk Assessment, SAR, Suspicious Activity Report