On 2nd March, the US Department of the Treasury, which is the parent department of The Financial Crimes Enforcement Network, FinCEN, issued the following statement:

The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.

“This is a victory for common sense,” said U.S. Secretary of the Treasury Scott Bessent.  “Today’s action is part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.”

The law remains in place but will not be enforced in respect of outstanding registrations or new registrations not made. 

But this applies only to US registered corporations. Foreign corporations in the USA must comply in full. And, unsurprisingly, there has been no mention made of foreign subsidiaries of US companies where that subsidiary has a presence in the USA. 

The end result is that KYC for corporate customers is now more complex. Or so one might think,

As the law is remains in place, the Financial Action Task Force is very unlikely to do more than blow some smoke; had the law been repealed or revoked, the FATF may have been more vocal, although it has rarely criticised the USA for its shortcomings. 

In practical terms, however, the decision will make little difference . The Registration was not to create a public register but one available, primarily, to law enforcement. Therefore, as a KYC tool, it was of limited value, But it was administered by Treasury (which already has the information which is of the most value in relation to US companies) and so was an expensive duplication of effort.

Therefore, as the USA had implemented the Companies Beneficial Ownership Register in such as way as to provide no particular value to anyone, its suspension of enforcement does not appear to do much more than create a PR issue because so few people understand why the USA's version of a registry was so fundamentally different to those in other countries. 

Had it been implemented as expected, the register would have been useful not only for financial sector KYC but also for credit and sanctions risk due diligence. It wasn't.