Update on Beneficial Owners

There has been a lot of regulatory activity surrounding beneficial owners the last several months.  This is because FinCEN was tasked with updating the way beneficial owners are tracked and monitored, in an effort to curb the use of shell companies for money laundering.  FinCEN’s implementation efforts can be broken down into three separate phases:

  1. The “Reporting Rule” is already in effect and requires legal entities to report and update, as applicable, beneficial ownership information (BOI) to FinCEN.  This does not impose any requirements for financial institutions.
  2. The “Access Rule” will take effect on February 20, 2024.  It governs who can access the BOI and how.  This only affects financial institutions that wish to access BOI from FinCEN.
  3. Updated “Customer Due Diligence Rules” will be coming but at this time no proposal has been issued.  This will directly affect financial institutions and bring current CDDBO rules in line with the other changes.

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Amy Kudlacek

Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!

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