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ARTICLE · 27 OCTOBER 2022

Beneficial Ownership Information: A Final Rule

Morrison Foerster
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On September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing beneficial ownership requirements for certain U.S. and foreign...

United StatesFinance and Banking
Deborah Connor
Deborah Connor
Marc-Alain Galeazzi
Marc-Alain Galeazzi
Malka Levitin
Malka Levitin
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On September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing beneficial ownership requirements for certain U.S. and foreign entities registered to do business in the United States, as mandated by the Corporate Transparency Act (CTA) (the "Final Rule"). FinCEN's primary goal in issuing the Final Rule is to assist in the prevention of money laundering and terrorist financing through anonymous shell companies. FinCEN published a fact sheet to accompany the 300-plus-page rule, and further guidance is expected to be released to advise regulated entities on compliance.

Background

The CTA was passed as part of the Anti-Money Laundering Act of 2020 (AMLA). Two additional rules mandated by the AMLA are expected to follow: one to revise the Customer Due Diligence Rule (CDD Rule) and another addressing access to the forthcoming beneficial ownership registry. The CDD Rule requires certain covered institutions, including banks and

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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