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:

1. The specific transactions exempted by the relief;
2. Triggers and decision trees for when a CDD refresh is still required; and,
3. 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Additionally, the relief will remain in force until it is revoked, superseded or replaced which means it could go away in the future at FinCEN’s discretion.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