FinCEN BOI Direct vs Commercial UBO Providers: Where Does US Beneficial Ownership Data Actually Come From?

Quick verdict

The US beneficial ownership data market in 2025 and 2026 is defined by one structural fact: there is less centralized UBO data available than there was supposed to be.

The Corporate Transparency Act (CTA), enacted in 2021, was designed to change this. It directed FinCEN to build a federal beneficial ownership information (BOI) registry and required most US businesses to file the identities of their beneficial owners. FinCEN opened the BOI system in January 2024. Then, following court injunctions in late 2024 and a Treasury enforcement suspension in March 2025, FinCEN issued an interim final rule on March 26, 2025, that exempted all US domestic entities from the BOI reporting requirement. What was supposed to be a registry of 32+ million US businesses became a registry populated only by foreign companies registered in the US.

The practical effect for compliance buyers is that the FinCEN BOI database is a partial and limited resource. It covers foreign entities that have registered to do business in a US state and have filed their BOI report. It does not cover the roughly 36 million US domestic businesses. For domestic entity UBO, commercial providers are the only structured option, and those providers face the same underlying problem: no state registry requires UBO disclosure, and FinCEN BOI no longer covers domestic entities.

[VERIFY: The March 2025 interim final rule was published for public comment. FinCEN stated it intends to finalize the rule in 2025-2026. Any revision could alter the current domestic exemption. Check https://www.fincen.gov/boi before citing in regulatory or compliance filings.]

The Corporate Transparency Act and what happened to it

The Corporate Transparency Act was part of the Anti-Money Laundering Act of 2020, enacted as part of the National Defense Authorization Act. It directed FinCEN to establish the beneficial ownership reporting requirement and a non-public registry accessible to federal and state law enforcement and, under limited conditions, to financial institutions verifying customer identities under the Bank Secrecy Act.

FinCEN opened the BOI filing system on January 1, 2024. The original rule required:

• Existing domestic and foreign reporting companies formed before January 1, 2024, to file by January 1, 2025.
• New domestic and foreign reporting companies formed on or after January 1, 2024, to file within 90 days of formation.
• Companies experiencing changes to their beneficial owners to update their filing within 30 days.

The reporting companies were defined broadly, capturing most US corporations, LLCs, and similar entities, with exceptions for large operating companies (those with 20+ full-time employees, $5 million in US-sourced revenue, and a physical office), regulated entities (banks, credit unions, investment advisers, etc.), and 23 other categorical exemptions.

What followed was a series of legal challenges. In December 2024, a federal district court in Texas issued a nationwide preliminary injunction against the CTA, finding it likely unconstitutional. The injunction was stayed, appealed, and litigated through the Eleventh Circuit (which found the CTA constitutional). In the meantime, Treasury suspended enforcement on March 2, 2025.

On March 26, 2025, FinCEN published an interim final rule in the Federal Register. The rule revised the definition of “reporting company” to cover only foreign companies registered to do business in a US state. All entities formed under the law of any US state or territory were exempted from the BOI reporting requirement.

Foreign companies that had registered to do business in the US before March 26, 2025, were required to file BOI reports by April 25, 2025. Foreign companies registered on or after March 26, 2025, must file within 30 calendar days of their registration becoming effective.

The result is a FinCEN BOI database that covers the foreign-company slice of US-registered entities, not the domestic business population the CTA was designed to capture.

Who can access FinCEN BOI and on what terms

FinCEN’s BOI access rules were set in the Beneficial Ownership Information Access and Safeguards Final Rule, separate from the reporting rule. Access is tiered:

• Federal agencies: access through secure FinCEN channels for law enforcement, national security, and intelligence purposes.
• State and local law enforcement: access through FinCEN portal with judicial authorization in many cases.
• Financial institutions: access limited to customer due diligence under the Bank Secrecy Act, specifically to verify a legal entity customer’s beneficial owners as required by FinCEN’s CDD rule (31 CFR 1010.230). The financial institution must obtain customer consent before accessing FinCEN BOI on that customer.
• Foreign governments: access through FinCEN international coordination channels.
• General public: no access. FinCEN BOI is a non-public database.

For financial institutions, the customer-consent requirement is a meaningful constraint. A bank cannot look up a counterparty’s FinCEN BOI without that entity’s authorization. The practical use case is limited to institutions verifying their own customers’ beneficial owners at account opening, not to general counterparty due diligence.

The commercial UBO providers described below are not FinCEN BOI distributors; they build their own ownership databases from other sources.

Commercial UBO providers: what they actually cover for US entities

The two most commonly cited commercial UBO providers for US compliance buyers are Sayari and Moody’s Bureau van Dijk Orbis.

Sayari

Sayari is a risk intelligence platform built from the ground up for investigative compliance use cases. Its coverage spans more than 250 jurisdictions and more than 2.3 billion company records. For US entities, Sayari sources data from:

• SEC EDGAR: public company subsidiary exhibits, ownership disclosures (Schedule 13D/13G), and other filings that reveal ownership stakes.
• State SoS registries: where officer and director data is published (not Delaware for most details).
• Trade records: US customs import data, bill-of-lading records, and maritime tracking that can reveal supplier and customer relationships.
• Corporate filings in international registries: where a US company’s foreign parent or subsidiary is registered, Sayari pulls the foreign registry data.
• News and media: open-source intelligence on ownership changes, enforcement actions, and relationships.

For US domestic private companies, particularly Delaware LLCs with no SEC filing history and no major international trade footprint, Sayari may have limited data beyond the SoS registration record. The platform is most powerful for entities with international connections, supply chain exposure, or public-company parents where ownership information is available in registry or SEC filings.

Sayari pricing is enterprise-only and not publicly listed. Market reporting places starting engagement costs at $50,000 or more annually. Sayari serves US government agencies (trade compliance, export control, sanctions enforcement), financial institutions, and global corporations. Its $50k+ entry point positions it firmly in the enterprise and government sector.

Moody’s Bureau van Dijk Orbis

Moody’s Bureau van Dijk Orbis is the most widely deployed global commercial ownership database. Orbis covers more than 450 million companies worldwide with structured financial and ownership data. It is used by banks, regulators, and audit firms for regulatory reporting, risk modeling, and UBO analysis.

Orbis sources its data from a network of more than 160 information providers worldwide, including official registry feeds where they exist, statutory filings, company reports, and research from BvD’s data collection teams. For US entities, the coverage sources include SEC EDGAR (for public companies), state SoS registry data (through third-party aggregators), and secondary research.

Orbis’s ownership data is structured and standardized across jurisdictions, which is its primary value for global compliance programs: the ownership percentage thresholds, beneficial ownership tracing methodology, and identification of ultimate beneficial owners (natural persons or listed companies where the chain terminates) follow a consistent framework across all 450 million entities.

For US domestic private companies, Orbis faces the same underlying data limitation as any commercial provider: without a national UBO registry, the ownership data for a US private entity comes from whatever the entity has voluntarily disclosed in filings, regulatory submissions, news sources, or research. For a closely held US LLC incorporated in Delaware with no public-company parent, the Orbis ownership entry may reflect only the registered agent or be absent.

Orbis pricing starts at approximately $20,000 per year for limited access and can exceed $100,000 annually for full global capability with all data modules.

The core gap: US private company UBO

The table below illustrates what each source actually provides for the most common US company types.

The bottom row of the compliance risk table is the US private LLC incorporated in Delaware with a beneficial owner who is not required by any state or federal registry to disclose their identity publicly. This entity type is the structural blind spot in the US UBO market. No commercial provider can reliably identify the natural-person ultimate beneficial owner of such an entity without the entity or its owners voluntarily disclosing that information somewhere accessible.

What the FinCEN CDD rule actually requires

The March 2025 CTA narrowing did not change the obligations of covered financial institutions under the FinCEN CDD rule (31 CFR 1010.230). That rule requires covered financial institutions to identify and verify the beneficial owners of legal entity customers at account opening. The rule has its own definition of beneficial owner (generally, a natural person who owns 25% or more of the equity interests, plus a single person with primary responsibility for managing the entity) that is independent of the CTA definition.

FFIEC examination guidance for BSA/AML programs expects financial institutions to document how they obtain beneficial owner information. The standard practice is to obtain a customer certification (the beneficial owner certification form) from the legal entity customer, which the customer self-certifies at account opening. The financial institution may then use Sayari, Orbis, LexisNexis, or CLEAR to corroborate or investigate the disclosed owners. The FinCEN BOI database is one available corroboration source for foreign companies that have filed, but it is not the primary mechanism for domestic entities.

The key point for compliance buyers: the CTA narrowing did not relax the CDD rule. Financial institutions still need to obtain and verify beneficial owner information for legal entity customers, even if those customers are not required to have filed with FinCEN. The difference is that financial institutions can no longer check a domestic entity’s FinCEN BOI filing as a corroboration tool (because there is no filing to check). They must rely on the customer’s self-certification, corroborated by whatever commercial data sources reveal about that entity’s ownership.

FATF Recommendation 24 and the US compliance gap

FATF Recommendation 24 requires countries to ensure adequate, accurate, and up-to-date information on the beneficial ownership and control of legal entities is available to competent authorities. FATF’s 2016 US mutual evaluation found that the US had material weaknesses in corporate transparency, particularly given the ease of forming anonymous shell companies in states like Delaware and Wyoming.

The CTA was positioned as the US’s principal response to that finding. With the March 2025 narrowing, the US again faces a question about its FATF R.24 compliance for domestic entities. FATF evaluates countries on a rolling basis; the US’s next mutual evaluation will assess whether the domestic exemption constitutes a gap relative to the R.24 standard.

For compliance buyers at US financial institutions with international correspondent banking relationships, counterparty due diligence requests from foreign banks may probe the adequacy of the US entity’s UBO identification practices. A foreign bank asking “please provide the beneficial owner of this US LLC” and receiving “we cannot verify this because there is no registry” is technically accurate but may not satisfy a correspondent bank’s enhanced due diligence requirements under their own regulatory framework.

Practical guidance for compliance buyers

Given the current state of the US UBO market, compliance buyers should design their programs around four realities.

Reality 1: FinCEN BOI is a limited supplementary check, not a primary UBO source. Use it for foreign companies registered in the US where you have customer consent. Do not plan your compliance program around FinCEN BOI for domestic entities.

Reality 2: Customer self-certification remains the primary UBO mechanism for domestic entities. The FFIEC/CDD rule framework requires the beneficial owner certification at account opening. Commercial corroboration tools (Sayari, Orbis, LexisNexis) supplement but do not replace the customer’s own disclosure.

Reality 3: Commercial UBO tools have real limits on US private companies. A Sayari or Orbis subscription is valuable for international ownership tracing and for entities with public-company parents or SEC filings. For a purely domestic private US LLC with no public-facing disclosures, commercial tools may not add material information beyond the SoS record.

Reality 4: State-level UBO initiatives may partially fill the gap. Some US states passed their own corporate transparency requirements independent of the CTA. New York’s LLC Transparency Act, for example, requires LLCs formed or registered in New York to disclose beneficial owner information to the state (with a delayed compliance timeline). [VERIFY: Check the current status of New York LLC Transparency Act enforcement timeline, as compliance deadlines have been extended multiple times.] Other states may follow. A compliance program covering entities in transparency-active states should track state-level UBO registry availability.

Comparison matrix

Frequently asked questions

Does the CTA domestic exemption mean US companies are anonymous now?

Not exactly. US public companies still file extensive ownership disclosures with the SEC (Schedule 13D/G for 5%+ holders, proxy statements for directors and officers). US companies with regulatory reporting obligations (banks, investment advisers, insurance companies, broker-dealers) disclose their owners to their regulators. State SoS records capture officer and director data where states require it. The CTA domestic exemption removes the FinCEN BOI filing obligation specifically; it does not remove other existing disclosure obligations.

For closely held US private companies, particularly Delaware LLCs and Wyoming LLCs, anonymity relative to any public or semi-public registry is effectively available. A single-member Delaware LLC can be formed with the registered agent as the only publicly visible contact. The beneficial owner, if a natural person, may not appear in any public record.

Can financial institutions access FinCEN BOI to verify their customers?

Yes, with conditions. Financial institutions that are covered by FinCEN’s CDD rule can access FinCEN BOI to verify the beneficial owners of their legal entity customers. The conditions are: the institution must obtain the customer’s consent before accessing their BOI record; the request must be linked to a specific account relationship; and the institution must use the information solely for BSA compliance purposes. Financial institutions do not have broad counterparty lookup access; the access is customer-specific and consent-gated.

Is the FinCEN BOI domestic exemption permanent?

The March 26, 2025 interim final rule was published for public comment, and FinCEN stated it intends to finalize the rule in 2025-2026. The final rule could maintain, narrow, or expand the current domestic exemption. The interim final rule took effect immediately upon publication and is operative pending finalization. Congressional action could also affect the CTA’s scope. This is one of the most actively monitored compliance rule developments in US AML policy. [VERIFY: Check https://www.fincen.gov/boi for the current status of the finalization process.]

What is the New York LLC Transparency Act?

New York enacted its own LLC Transparency Act, which requires LLCs formed or registered in New York to disclose their beneficial owners to the New York Department of State. The law was intended to fill some of the gap left by the CTA’s uncertain enforcement trajectory. Compliance timelines have been extended multiple times and as of mid-2026 implementation details remain in flux. [VERIFY: Check the New York Department of State website for current LLC Transparency Act enforcement dates before advising clients on compliance timelines.]

Do Sayari and Orbis have the same data?

No. Sayari and Orbis build their databases from different source networks and emphasize different use cases. Sayari emphasizes investigative research, trade data, and supply chain risk; its interface is designed for case-level investigation with graph visualization. Orbis emphasizes structured financial and ownership data across a standardized global database; its interface is designed for portfolio-level analysis, regulatory reporting templates, and group-level financial consolidation. For US entity research, Sayari’s trade data integration gives it a lead on supply-chain-linked entities; Orbis’s financial data integration gives it a lead on entities with disclosed financial statements. A compliance program that needs both investigative research and financial analysis will often use both.