On May 29, 2026, the GAO published Corporate Transparency: Treasury Should Address Gaps in Ownership Information Resulting from Expanded Exemptions. The report looks at what happened after the Corporate Transparency Act, which directed the Financial Crimes Enforcement Network (FinCEN) to collect beneficial ownership information and build a registry of the people who actually own or control business entities.

The registry was supposed to close a long-standing blind spot. US companies usually do not have to disclose who owns them, and that secrecy is useful to anyone trying to hide money. The law took effect in January 2024, and FinCEN started collecting ownership information that year. Then, in March 2025, it issued an interim final rule that exempted domestic companies and US persons from reporting. What was left was a narrow requirement covering only foreign companies registered to do business in the United States.

The scale of that change is staggering. According to the GAO, the expanded exemption applies to over 99 percent of entities that previously had to report. Most of them are limited liability companies and corporations, the two largest categories of registered businesses in the country.

State records do not fill the hole. Most states ask companies to file reports that may list officers, directors, or LLC managers and members, but those people are often not the beneficial owners, and the rules differ from state to state. So the person who controls a company can stay invisible even when a filing exists.

The GAO ties this directly to crime. Treasury’s own 2026 National Money Laundering Risk Assessment describes cases where US shell companies, usually set up as LLCs or corporations, were used to launder proceeds from drug trafficking, cybercrime, and fraud. The GAO recommended that Treasury identify actions to address the gap created by the new exemptions. The Treasury disagreed. The recommendation is still open.

In an April 2025 report, Fraud in Federal Programs: FinCEN Should Take Steps to Improve the Ability of Inspectors General to Determine Beneficial Owners of Companies, the same forensic team described a scheme in which a company owner hid his identity to win a contract set aside for disabled veterans, along with other cases that turned on hidden foreign ties. The finding was blunt. When it is unclear who ultimately owns or controls a company in a federal program, the risk of procurement, grant, and eligibility fraud goes up.

That report also showed how many people need this information. The GAO surveyed 72 Offices of Inspectors General, held a roundtable with seven of them, and interviewed FinCEN and the Council of the Inspectors General on Integrity and Efficiency. Most of the inspectors general said access to beneficial ownership data would help their fraud detection work. So this is not one audit team with an unusual need. It is a problem the federal oversight community keeps running into.

The answer matters for practical reasons. Some federal contracts require suppliers to be US owned and operated. To check that, investigators need to know whether a US-registered entity is actually controlled by a company somewhere else. They also need to follow parent and subsidiary structures, because a recipient that looks independent may sit inside a larger group, and the relationships that matter are rarely listed in one tidy place.

The GAO does this at scale. Its teams work across bulk data rather than checking companies one at a time, so they need ownership and control information in a structured form they can run analysis against, not just a website they can search by hand.

The problem with reconstructing ownership when the records are thin.

The work the GAO does is exactly the work the reports describe as getting harder. When official beneficial ownership reporting has gaps, the underlying question does not go away. Investigators still have to reconstruct who owns and controls an entity, and they have to do it without a complete federal registry to lean on.

The inspectors general were specific about why this is hard. They told the GAO that the federal, state, and commercial data sources available to them are difficult to use for identifying beneficial owners. Two cases are especially difficult. The first is private companies. The entities receiving grants and contracts are often privately held, and reliable ownership data for private companies is genuinely hard to get. The second is cross-border structures, where a US branch or subsidiary traces back to a parent in another country. Seeing that a US entity is foreign owned at all is frequently the hardest step, and it is often the step that matters most for the question being asked.

There is also a sourcing constraint that serious investigators care about. Some commercial ownership datasets draw on leaked material such as the Panama Papers or the Paradise Papers. For an audit body whose findings have to hold up under scrutiny, data with that kind of provenance raises fruit-of-the-poisonous-tree concerns. The source has to be clean.

How OpenCorporates data helps

OpenCorporates publishes legal entity data from official primary sources, and it now offers a relationship file that surfaces ownership and control connections in bulk. Three kinds of records do most of the work for an investigator:

1. Branch data comes directly from secretaries of state. It is broader than the SEC data and reaches across borders, which is what allows an investigator to see a branch operating in the United States whose parent company sits in Europe or elsewhere. Seeing that link, even before pulling the foreign company’s full record, is often the result that matters.
2. Parent and subsidiary relationships come from SEC filings, so they cover publicly traded companies and the groups built around them. This is what lets an analyst follow a recipient up to its corporate parent or down to its subsidiaries.
3. Control statements capture beneficial-ownership-style information. This is closest to true UBO data and is strongest for the United Kingdom, where that reporting exists.

All of it comes from official primary sources, with no leaked material in the mix, and it arrives as quarterly snapshots so the data stays current. Coverage is strongest in the United States, the United Kingdom, and Western Europe, and thinner past that.

The detail that makes this usable at scale is the shared identifier. Every record is keyed to the OpenCorporates identifier, the combination of jurisdiction code and company number. The relationship file uses the same key as the bulk company data the GAO already receives, so the connections link cleanly to the existing records instead of sitting in a separate silo. An investigator can move from a company to its relationships and back without stitching datasets together by hand.

This is close to the capability the inspectors general told the GAO they were missing. They pointed out that FinCEN had not built a way to download the registry in bulk, and that a bulk download would let them match ownership data against the other datasets they already run. Bulk delivery on a shared key is what makes that kind of matching possible.

The GAO reports describe a shrinking pool of official ownership information at the federal level. Open, structured, primary-source data does not replace a national beneficial ownership registry, and it does not claim to. What it does is give investigators a way to keep reconstructing ownership and control from records that are already public, keyed so the pieces connect, and clean enough to stand behind. When the official trail thins out, that is a practical part of the answer.

This is not a passing concern. Across two reports in 2025 and 2026, the GAO has flagged the same ownership gap, and in both cases its recommendation to Treasury and FinCEN is still open. The GAO has also indicated it expects more work in this space, including using OpenCorporates data for reliability checks inside its audits. The transparency question the reports raise is not settled, and the people whose job is to follow the money are still going to need to see who is on the other end of it.