01 · Ownership: The US ownership registry is gone. Now what?
On August 11, FinCEN issued a final rule that removes US-formed companies from beneficial ownership reporting under the Corporate Transparency Act. Foreign companies registered to do business in the US still have to report. FinCEN will also delete the information it holds on people it reasonably believes are US persons.
What did not change: banks and other covered institutions still have to collect and verify beneficial ownership for legal entity customers under the 2016 CDD Rule. FinCEN pointed to that rule as the safeguard for exempting domestic companies.
How this impacts compliance teams:
Teams that relied on the federal registry for US entities will need other sources for ownership information.
State rules are filling some of the gap. New York's LLC Transparency Act took effect in January, and D.C. already requires ownership reporting.
Multi-layered structures matter more. A US company owned by a holding company abroad still has to be traced to the real person behind it, layer by layer.
The question for your team: If a US business customer's owners changed last month, how would you find out?
Read what the CDD Rule requires now that BOI reporting is gone here.
02 · EU rules: The EU writes down its CDD rules
At the end of September, AMLA published three sets of final draft standards under the AML Regulation. The most important for onboarding teams covers customer due diligence: what information and documents firms must collect, and how the rules apply in practice. A second set defines when a business relationship or linked transaction starts, which decides when CDD applies at all.
Next, the European Commission adopts the standards and they are published in the Official Journal. They are expected to apply six months after they enter into force, with some provisions from July 2029.
How this impacts compliance teams:
Teams that onboard EU customers are starting to compare their current KYC and KYB steps with the final CDD standards, while there is still time to adjust workflows.
The triggers matter. For some products, the point where CDD starts may shift.
Examiners are likely to ask how each step was applied, as well as whether it was done.
The question for your team: Which step in your onboarding flow would be hardest to explain to an examiner, start to finish?
03 · UK: The ID deadline is a month away
Since November 18, 2025, new directors and people with significant control (PSCs) of UK companies have had to verify their identity with Companies House. Existing directors and PSCs got a 12-month transition period, which ends in mid-November. By the end of June, only 55% of directors, 50% of LLP members and 42% of PSCs had verified, according to Companies House figures.
How this impacts compliance teams:
Gaps on the register are likely. After the deadline, the public register shows whether each director and PSC has verified, and an unverified role at a UK business may prompt a closer look.
A UK business onboarded earlier this year may show a different status by December, which can come up at its next periodic review.
Companies House verification confirms a person's identity. It does not trace who ultimately controls the company.
The question for your team: How many of your UK business customers have an unverified director on the register today?
What's new at AiPrise
Supply Pay chose AiPrise. Supply Pay, the platform for cross-border supply chain financing and payments, now runs its global KYB and KYC on AiPrise.
Read the announcement here.
Where to find us: Money20/20 USA
Our team will be at Money20/20 USA in Las Vegas, October 18 to 21, at The Venetian Expo. We don't have a booth this year, so it is the best time to book a meeting with us.
We are also co-hosting AI After Dark with Unit21, TRM Labs, LexisNexis and AFC on Tuesday, October 20, from 6:00 to 8:30 pm at Nomikai Speakeasy in The Venetian.
One more thing: the busiest address in corporate America
A single office building at 1209 North Orange Street in Wilmington, Delaware is the registered address of more than 285,000 companies, according to a 2012 New York Times report. It's a good reminder of why an address alone tells you very little about who is behind a business.
What should we dig into next month?
This newsletter is for general information only and isn't legal or professional advice.