Date:

14.03.2026

Reading time:

7 minutes

Author:

Daniil Kadyrov

Managing Partner

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How to Submit Information to the Register of Beneficial Owners of American Companies

How to Submit Information to the Register of Beneficial Owners of American Companies

Corporate Law Banks, financial markets and fintech International Law UBO Registration of legal entities Due diligence

Date:

14.03.2026

Reading time:

7 minutes

Article

Legislative Basis Who Qualifies as a Beneficial Owner (UBO) Submission Deadlines Where to Submit the Information Is a Special Status Required to Submit the Information What Information Must Be Provided How Often Information on Beneficial Owners Must Be Submitted What Happens After Submission Practical Assistance

Questions and Answers Terms Read also

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«Kadyrov, Drokonov and Partners»

Legislative Basis

As of 1 January, the Financial Crimes Enforcement Network of the United States Department of the Treasury (FinCEN) began accepting information on the beneficial owners (UBO) of American companies. The obligation arose under the Corporate Transparency Act 2021 (Corporate Transparency Act, CTA).

Who Qualifies as a Beneficial Owner (UBO)

A beneficial owner under American law is an individual who exercises substantial control over a company, or owns or controls at least 25% of the company’s shares.

Submission Deadlines

Companies registered before 01.01.2024 — must submit information by 01.01.2025.

Companies registered after 01.01.2024 — must do so within 90 calendar days after registration.

Where to Submit the Information

Information is submitted through the BOI E-Filing System. Available methods:

upload of a PDF;
completion of an online form on the website;
automated methods (through a corporate service provider).

It is recommended to submit through the online form — it is faster and more reliable.

Is a Special Status Required to Submit the Information

Registration in the service is free. American documents or accounts in other systems are not required. Any applicant may submit information on behalf of the company.

What Information Must Be Provided

The form must include:

company information;
applicant information;
beneficial owner information (name, date of birth, address, identification document details, and its scan).

How Often Information on Beneficial Owners Must Be Submitted

The information is submitted once. It must be updated only when data changes or in case of corrections. Possible submission types:

initial submission;
correction;
update of information;
submission of an exemption report.

What Happens After Submission

After submission, the applicant receives a confirmation and an individual filing number. Status updates are sent by e-mail, but it is recommended to check the system independently. The generated PDF report must also be downloaded.

Practical Assistance

If you need to submit information on beneficial owners or resolve other corporate matters, including registration and support of a company in the United States, you may contact our law firm.

FAQ

Which companies are exempt from submitting information on beneficial owners in the United States?

The Corporate Transparency Act provides exemptions for the following: public companies, banks, insurance organisations, and certain other categories already subject to strict regulation.

Can an error in previously submitted information on beneficial owners in the United States be corrected?

Yes. The BOI E-Filing System provides for the submission of corrective forms. It is the company’s obligation to correct inaccuracies as soon as they are identified.

Who may act as the applicant when submitting information on beneficial owners in the United States?

Any authorised person of the company may submit the information. United States citizenship or local documents are not required — the BOI E-Filing System is accessible to all applicants.

Is it necessary to update information on beneficial owners of American companies in FinCEN?

Yes, if the company’s or its UBO’s data has changed (for example, a change of address, passport, or participants). In other cases, the information is submitted once.

What liability is provided for failure to submit information on American beneficial owners to FinCEN?

Failure to provide or late provision of information on beneficial owners (UBO) may result in fines of up to 500 United States dollars for each day of delay, as well as criminal liability in cases of intentional evasion.

All questions and answers

Key Terms

Beneficial Owner

The actual owner or beneficial recipient who directly or indirectly controls a company’s activities and receives economic benefit from its operations, regardless of whether he is listed in official documents.

BOI E-Filing System

The electronic system for submitting information on beneficial owners of American companies developed by FinCEN. Intended for online forms, document uploads, and automated submissions.

Corporate Transparency Act (CTA)

A 2021 federal United States law requiring companies to disclose information on their beneficial owners to combat money laundering and terrorist financing.

FinCEN (Financial Crimes Enforcement Network)

An agency of the United States Department of the Treasury responsible for combating financial crimes and administering the system for submitting information on beneficial owners.

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