Beneficial Owner Relief
On February 13, 2026, FinCEN issued an order of “Exceptive Relief from Requirements to Identify and Verify Beneficial Owners at Each Account Opening” (FIN-2026-R001).
The Order states, …Rather than having to identify and verify a legal entity customer’s beneficial owners each time that customer opens an account, covered financial institutions may instead limit their identification and verification of the identities of beneficial owners under 31 C.F.R. § 1010.230(b) in certain circumstances.
Financial institutions must; however, …continue to comply with all other applicable anti-money laundering/countering the financing of terrorism (AML/CFT) requirements under the Bank Secrecy Act (BSA) and its implementing regulations, including program, recordkeeping, and reporting requirements.
This exceptive relief was effective immediately; however, if you want to take advantage of it, it’s not just a simple flip of the switch. Doing so is going to require changes to your policies, procedures and processes.
Published 2026/02/19
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).