FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

Highlights

• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a notice to customers of financial institutions (the Notice) containing a reference guide for reporting beneficial ownership information (BOI) under customer due diligence (CDD) and the Corporate Transparency Act (CTA).
• The Notice informs entities that BOI must be submitted to FinCEN under the CTA and financial institutions under CDD and compares 1) the types of information submitted about beneficial owners, 2) the types of information submitted about entities and 3) other information and certifications required by FinCEN and by financial institutions. The Notice also specifies the deadlines for reporting BOI to FinCEN under the CTA.