US-created entities remain exempt under the August 2026 final rule; do not rely on an old universal-LLC filing checklist. FinCEN announced the final rule on August 11, 2026, and it became effective August 14. It finalized the narrowed reporting framework and added relief involving US-person company applicants and FinCEN identifiers. Foreign-created entities registered to do business in the US require a separate scope review. FinCEN announcement; final rule. (fincen.gov)
Recommended transaction action: Document jurisdiction of formation, US registration where relevant, exemption analysis and remaining filing obligations for each entity. Do not automatically discard lender, insurer or licensing ownership-information requests because the federal CTA reporting position changed.
For family offices, this belongs in the entity-formation and closing checklist—not the property’s recurring operating-expense budget.