Regulatory update – USA
On January 1, 2026, New York became the first U.S. state to require annual disclosure of beneficial ownership information (UBO/BOI) for limited liability companies (LLCs) under the New York LLC Transparency Act (NY LLCTA).
- Odyssey
Who’s impacted
- All NY LLCs and foreign LLCs registered in New York
- Exempt: listed companies, banks, nonprofits (exemptions still require annual attestation)
What must be disclosed
- UBOs owning/controlling 25%+ or exercising substantial control
- Name, DOB, address, government ID
- If a UBO is a company → individual owners must be disclosed
Key points
- Information is confidential (not public)
- Accessible only to authorities & financial institutions for due diligence
- Penalties up to USD 500/day and possible loss of authority to operate
Why it matters
With the federal CTA largely suspended for U.S. entities, New York is stepping in. Other states may follow, state-level UBO transparency is coming.
