Ownership research got harder in 2026
For a short period, US companies filed beneficial ownership information with FinCEN under the Corporate Transparency Act. For domestic companies that ended with FinCEN's interim final rule in March 2025, and a final rule effective 14 August 2026 made the exemption for US companies and US persons permanent. Only foreign entities registered to do business in the United States still report, and they do not report US owners. The filings were never public, so the practical position for a buyer or supplier is unchanged: there is no federal register where you can look up who owns a US company. You have to build the picture yourself. Our article on beneficial ownership after the CTA rollback explains what banks and states still collect.
Most evidence sits in public records
State business registries show formation dates, registered agents and, in some states, managers or officers. SEC EDGAR holds filings from public companies and Form D notices of private offerings. Court dockets show litigation, judgments and bankruptcies. UCC filings show who has lent against a company's assets. For foreign counterparties, registers such as UK Companies House publish the people with significant control.
Sanctions lists from OFAC, the UK and the EU are checked by name and by ownership. Under OFAC's 50 Percent Rule, an entity owned 50 percent or more, directly or indirectly, by one or more blocked persons is itself blocked, even if it appears on no list. A clean name search is therefore not a clean result until the ownership chain has been followed.
Your ledger is a source too
Some of the most useful evidence already sits in your own systems. When we research a vendor we also look at how you pay it: whether its bank account, address or phone number matches an employee's, whether its bank details changed shortly before a large payment, and whether its invoices cluster just below an approval limit. Public records tell you who a company is. Your ledger tells you how the relationship has actually worked. Where the ledger raises more questions than it answers, full-ledger analytics tests every transaction rather than one vendor's.
Benchmarks need a published method
A benchmark is only as good as its sample and its definitions. "Days to close" means nothing unless everyone counts from the same day to the same event. When we run benchmark and sector research for an association, funder, lender or board, the method travels with the report: how participants were chosen, how many responded, how each measure was defined, what was excluded and who paid for the work. Small groups are combined so that no participant can be identified, and if the data cannot support a conclusion, the report says so.
For a first look at your own organization before any formal comparison, the Controls Health Self-Check scores your answers across the five COSO components.


