It has been five years since the Anti-Money Laundering Act of 2020 (AMLA) and its centrepiece, the Corporate Transparency Act, came into force as part of the omnibus National Defense Authorization Act for fiscal year 2021. With the benefit of distance, three measurable outcomes can now be assessed: reporting compliance, enforcement activity, and the use of beneficial-ownership data by law enforcement.
Reporting compliance is now broadly in line with FinCEN projections
FinCEN’s most recent enforcement bulletin, issued in November 2025, reported that an estimated 35.8 million reporting companies had filed an initial beneficial-ownership report, close to the 32.6 million entities the Treasury originally projected as in-scope. After a difficult first year in which compliance with the 1 January 2024 deadline was estimated at under 25%, a combination of judicial clarification, deadline extensions and aggressive registered-agent outreach lifted that figure significantly.
The compliance picture is uneven by sector. Special-purpose entities used in private-equity and real-estate structuring report at near-100% rates, reflecting institutional legal advice; small operating businesses and inactive holding companies remain materially under-reported.
Enforcement: targeted rather than mass
FinCEN has so far adopted an enforcement posture more like the OFAC sanctions model than the IRS information-return model. Through 2025 it issued only a small number of civil penalties for non-reporting, and these were concentrated on entities whose underlying transactions were already under investigation for other reasons. The chilling effect on opaque structures appears, on the evidence available, to be real but modest.
Law enforcement use is real but quiet
Statutory access to the BOI database is restricted to specified federal, state, local and foreign authorities and to financial institutions for customer due-diligence purposes. Department of Justice statistics released under FOIA show 8,400 BOI queries by federal law-enforcement agencies in 2025 alone, with the largest single user being the Internal Revenue Service’s Criminal Investigation division. Several public indictments, notably in narcotics, sanctions-evasion and Chinese-precursor cases, have cited BOI records.
The live legal threats
Two federal courts have issued rulings challenging the constitutionality of the CTA on Commerce Clause grounds (NSBA v. Yellen and Texas Top Cop Shop v. Garland). The Supreme Court has so far declined to take the question on the merits but has narrowed the scope of preliminary relief. A definitive ruling in the 2026 term remains possible and would, in a worst case for proponents, require Congress to re-anchor the statute under the Taxing Clause.
For now, the AMLA framework is operating. Whether it survives the constitutional test, and whether the data it generates is genuinely changing the calculus of US-based illicit finance, will be the questions that define the next five years.
