FinCEN Corrections to Beneficial Owner Certification Form

FinCEN recently published changes to the Beneficial Owner Certification Form (Appendix A to 31 CFR 1010.230). These technical corrections were effective September 28, 2017, and include the following:

 

  • Part I

In the first sentence under the “What information do I have to provide?” heading, the term “foreign persons” is changed to “non-U.S. persons”.

 

  • Part II

The heading for Section II b. is changed to “b. Name, Type, and Address of Legal Entity for Which the Account is Being Opened:”.

 

  • Tables in Section II c and Section II d

In the headings of the last column, the term “Foreign Persons” is changed to “Non-U.S. Persons” and the term “Social Security Number” is added after the term “persons”.

 

  • Footnote 1

The term “Foreign Persons” is changed to “Non-U.S. Persons” and “a Social Security Number,” is inserted after the word “provide”.

 

It’s important to note the addition of the “type” of legal entity business (corporation, LLC, etc.) as a required piece of information and the addition of “Social Security Number” as an acceptable identifying number for non-U.S. persons. This will require adjustments in the implementation plans of financial institutions and third-party service providers.

 

Due to these changes, we have updated our Certification of Beneficial Ownership form that’s available in the BSA Tools (Free Downloads) on our website.

 

Also, if you are looking for an update on all the BSA happenings in 2017 and what’s to come with the May 11, 2018, Final Rule, you’re in luck! Join us for our full day BSA/AML Compliance Conference in November.

Published
2017/10/09
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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