Beneficial Owner Exceptive Relief
The “Exceptive Relief from Requirement to Identify and Verify Beneficial Owners at Each Account Opening” (FIN-2026-R001) issued by FinCEN on February 13, 2026, was effective immediately; however, there are some things to consider before you make a change. First and foremost, your Customer Due Diligence/Beneficial Owners policy/procedures will need to be updated to include:
- The specific transactions exempted by the relief;
- Triggers and decision trees for when a CDD refresh is still required; and,
- Documentation standards for applying the relief.
Additionally, the relief will remain in force until it is revoked, superseded or replaced which means it could go away in the future at FinCEN’s discretion.
Kevin explains more in the video.
Published 2026/03/30
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).