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:
- 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.
- 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.
- 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.
Published
2024/01/24