On March 2, 2025, the U.S. Treasury announced that US corporations are no longer required to file Beneficial Ownership Information (BOI) reports under the Corporate Transparency Act. 

It’s dramatic - and here’s what that means to you.

First, this changes nothing about your obligation to “know your customer.” For BSA officers, it means that while all the US corporations can hide their owners, you are still on the hook for performing effective Customer Due Diligence (CDD).

So your job just got harder. If you open an account or approve a transaction for a company owned by someone on the SDN list, you’re still liable. So, now you are playing defense, but with your eyes closed.

What’s the SDN list? The Specially Designated Nationals (SDN) List is a key component of U.S. economic and trade sanctions enforced by the US Treasury’s Office of Foreign Assets Control (OFAC). The last one I looked at was over 2,000 pages and included individuals, companies, and even vessels that you can’t do business with.

Why? Because they are credibly (hopefully) connected with, owned by, controlled by, or acting on behalf of those involved in terrorism, narcotics trafficking, money laundering, or other threats to U.S. national security and foreign policy.

You can’t engage in transactions with anyone on the SDN List, and their assets under U.S. jurisdiction are blocked. 

So now the US is taking the position that US corporations don’t have to disclose who their beneficial owners are. Who is helped by this decision? You, if you found the six minutes needed to file the report to be too onerous. Oh, and criminals hiding criminal money from criminal investigators. 

For BSA officers, this regulatory shift doesn’t remove your risk—it increases it. You have all the liability and exposure to the downside if you do business with an entity on the SDN list. You all know, or should, the saga of TD Bank. Most recently it was fined, and I’ll say it, shamed, for violating its duties under the BSA and the restrictions on doing business in violation of the OFAC SDN list. They are not alone in their malfeasance, and there’s a long and storied list of violations found on FincEN’s website. 

Bigger Picture - Not Your Job

What the Fed is doing, is not done in a vacuum. US actions are tracked. Transparency International (www.transparency.org) keeps a  Corruption Perceptions Index (CPI). It is a benchmark for evaluating public sector corruption worldwide, assigning scores from 0 (highly corrupt) to 100 (very clean) to 180 countries. In the 2024 CPI, the United States is ranked 28th most clean, with a score of 65, a four-point decline from the previous year. This represents the lowest ranking for the U.S. since the inception of the index, indicating growing concerns about corruption in the US.

And our 2025 ranking should be even worse. In February 2025, the current president issued an executive order pausing the enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days, pending a review aimed at enhancing American competitiveness. This move has raised concerns about the potential increase in corporate bribery and a decline in ethical business practices. The Guardian wrote: “the abandonment of the anti-kleptocracy initiatives might be good for US condo sales. But if the "current administration" thinks giving aid and comfort to autocrats and corrupt officials abroad who want to stash their money here is in our national interest, it has a sleazy real estate broker’s view of the national interest.

Transparency recently published “Unveiling Opacity in Real Estate Ownership.” (https://www.transparency.org/en/news/unveiling-opacity-in-real-estate-ownership-index). They make the case that “For criminals and the corrupt, real estate remains the investment of choice and the perfect safety deposit box to stash dirty money.” They have a term they call OREO, or Opacity in Real Estate Ownership - and they keep an index to give countries a grade. The US’s grade is not good. 

So what should BSA officers be doing? 

Don’t take your eye off of CDD, or “customer due diligence.” Use commercial tools, trusted public records, and all your investigative techniques to find beneficial owners. Raise a stink if you suspect someone of hiding behind corporate curtains. And finally, train your teams in fraud, in the methods of deception, and help them hone their instincts. 

Just because the Feds say US corporations can hide their owners, that does not mean that you have to agree. After all, it’s your backside if you do business with someone on the SDN list.