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Daniel McDonough

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Dan has spent his career helping private equity funds and strategic M&A participants complete their most important transactions. From the acquisition or sale of portfolio investments to carve outs of individual brands, corporate governance matters, and complex commercial arrangements, buyers and sellers rely on Dan to help them structure and navigate their most significant opportunities.

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On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Final Rule) confirming the implementation of the relief and clarifications regarding the Corporate Transparency Act (CTA) contemplated by the March 21, 2025 interim rule (Interim Rule) covered in our March 25, 2025, and April 22, 2025, client alerts. The Final Rule took effect on August 14, 2026, upon its publication in the Federal Register. By removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the CTA, the Final Rule represents a significant rollback of much of a reporting regime that had imposed compliance obligations on millions of small and mid-sized businesses across the U.S. FinCEN has also announced it will delete previously reported information submitted by U.S. persons from its BOI database.

On November 8, the Financial Crimes Enforcement Network (FinCEN) issued a final rule outlining the conditions under which a reporting company can report another entity’s FinCEN identifier instead of an individual’s beneficial ownership information (BOI). A FinCEN identifier is a unique number issued by FinCEN to an individual or a reporting company that has provided its BOI to FinCEN.

Yesterday, the Financial Crimes Enforcement Network (FinCEN) published a Small Entity Compliance Guide and updated its list of Frequently Asked Questions (FAQs) to assist entities in determining what steps will be required to comply with the beneficial ownership reporting requirements of the Corporate Transparency Act. The newly published guide includes various flow charts, tables, and hypothetical scenarios that are meant to assist members of the small business community with the analyses all companies must undertake in order to comply with the act, including determining whether a given company is or is not a “reporting company,” and determining each reporting company’s beneficial owners. FinCEN also published new FAQs and revised prior FAQs regarding the act and related reporting mechanics.