Compliance Brief - August 12, 2026 - Global RADAR
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Compliance Brief – August 12, 2026

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Edition 12 · August 12, 2026

In This Edition

FinCEN Ends BOI Reporting for US Companies

What’s new in compliance. Why it matters. What it means for your operations.

This is Edition 12 of your Weekly Compliance Brief, Wednesday, August 12, 2026.

From the Founder
Washington just handed beneficial ownership back to the private sector. With the registry closed and US-person records being deleted, your CDD files are the only ownership evidence left in the system. Boards should ask one question this quarter: can we prove who owns our customers without FinCEN’s database? Most institutions cannot answer that today.
Dominic Suszek · Founder and CEO, Global RADAR

This Week in 30 Seconds

  • FinCEN permanently ends BOI reporting for US companies and will delete US-person data
  • OFAC maps Iran’s shadow banking through UAE, Hong Kong, and Singapore fronts
  • Senate passes Russia and Iran sanctions bill 86-11; House votes in September

1. Top story of the week

FinCEN just closed the book on beneficial ownership reporting for US companies. On August 11, FinCEN issued a final rule permanently removing the Corporate Transparency Act reporting requirement for US companies and US persons, and confirmed it will delete US-person records already sitting in the beneficial ownership database. Foreign entities registered to do business in US states must still report their foreign beneficial owners. The rule takes effect on Federal Register publication.

Why This Matters

The registry many institutions hoped would one day verify customer-provided ownership data is gone for good. The CDD Rule still stands; your onboarding files are now the only beneficial ownership record in the US system, and examiners know it.

Operational Implications

Three steps for this week:

  1. Brief your board and audit committee this month: registry verification of ownership data is permanently off the table, and CDD files now carry the full evidentiary weight.
  2. Update onboarding procedures and CDD checklists by quarter-end to remove any reliance on FinCEN registry lookups; several vendors wired those checks in prematurely.
  3. Push enhanced due diligence on foreign entities registered in US states; they are now the only reporting population and deserve a dedicated screening rule.

2. Enforcement and penalties

  • OFAC, August 7: Designated seven entities and five individuals running Iran’s “rahbar” shadow banking network through UAE exchange houses and fronts in Hong Kong, Singapore, and Dubai.
  • OFAC, August 7: Separately designated a multinational cryptocurrency exchange network and a digital asset exchange for supporting the IRGC and Iran’s financial sector.
  • State Department, August 6: Designated five entities and six individuals tied to Cuba’s arms imports; OFAC FAQ 1264 preserves humanitarian trade carveouts.
Why This Matters

Almost none of these designations sits inside Iran or Cuba. The network runs through exchange houses and shell companies in hubs most institutions rate medium risk; country-based risk scoring misses exactly this exposure.

Operational Implications

Three steps for this week:

  1. Run a look-back on UAE, Hong Kong, and Singapore correspondent and trade finance counterparties against the August 7 designations before Friday.
  2. Document exchange house exposure in your risk assessment; examiners will ask how you rate money service businesses in Gulf hubs, and “medium” no longer survives scrutiny.
  3. Update crypto counterparty screening to capture the newly designated exchange network; exchange-level designation is becoming OFAC’s default tool.

3. New guidance and rulemaking

  • US Senate, House vote expected September: Passed the Sanctioning Russia and Iran Act 86-11, authorizing tariffs up to 100 percent on buyers of Russian oil.
  • Federal Reserve, comments due September 8: AML and CFT program modernization proposal remains open; the other banking agencies’ parallel proposal closed in June.
  • OFAC, effective September 17: Venezuela General License 5Y delays the PdVSA 2020 bond authorization by only six weeks, hinting it may finally take effect.
Why This Matters

Program rules and sanctions authorities are moving at once. If the House passes the Russia bill in September, secondary exposure will reach oil buyers and facilitators far outside Russia, and screening perimeters will need to widen quickly.

Operational Implications

Three steps for this week:

  1. Draft your Federal Reserve comment letter now; internal review always takes longer than the four weeks left before September 8.
  2. Map clients with Russian oil supply chain exposure ahead of the House vote; waiting for enactment is a losing strategy when tariff authorities reach facilitators.
  3. Escalate any PdVSA 2020 bond holdings to counsel before September 17; the long-delayed authorization window may finally open.
Theme of the Week
Washington is centralizing enforcement while decentralizing data. The same week FinCEN moved to delete a database covering millions of companies, OFAC designated shadow banking fronts across three financial hubs. The burden of knowing who owns what now sits entirely with institutions; a CDD file you cannot defend is the new single point of failure.

4. Global watch

  • UK, week of August 4: New Russia package designates 12 entities and six vessels, including six banks.
  • EU Council, August 7: Listed five individuals supporting Russia’s ballistic missile and drone production.
  • China, August 5: Announced countermeasures against US entities and tightened drone-related export controls.
  • AUSTRAC, August: Now supervising nearly 100,000 entities; unenrolled tranche 2 firms face daily penalties.

5. Coming up in the next 30 days

Date Event or deadline
Mid-August 2026 FinCEN BOI final rule takes effect on Federal Register publication; US-person data deletion begins.
September 3, 2026 EBA consultation on benchmarking framework amendments closes for comment.
September 8, 2026 Federal Reserve AML and CFT program modernization proposal closes for comment.
Early September 2026 House returns from recess; the Sanctioning Russia and Iran Act awaits a vote.
September 17, 2026 Venezuela General License 5Y: PdVSA 2020 bond authorization takes effect absent another delay.
October 2026 FATF plenary convenes in Paris, the first under the incoming UK presidency.

Next Wednesday

Next Wednesday: the BOI final rule should be in the Federal Register with data deletion underway; we will cover what examiners now expect CDD files to prove, plus any movement on the House sanctions bill.

Want a 30-minute review of your beneficial ownership and CDD controls now that the FinCEN registry is going away? Book a call with a Global RADAR compliance specialist.

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