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ARTICLE · 08 JANUARY 2024

FinCEN Issues Final Rule About Accessing Beneficial Ownership Information

Mayer Brown
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On December 21, 2023, the Financial Crimes Enforcement Network ("FinCEN") released a final rule to implement the beneficial ownership information ("BOI")...

United StatesFinance and Banking
Matthew Bisanz
Matthew Bisanz
Brad Resnikoff
Brad Resnikoff
Grace Kim
Grace Kim
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On December 21, 2023, the Financial Crimes Enforcement Network ("FinCEN") released a final rule to implement the beneficial ownership information ("BOI") access requirements of the Corporate Transparency Act ("CTA") (the "Access Rule").1

The Access Rule addresses how authorized recipients can access and use BOI that will be reported to FinCEN, and how FinCEN and authorized recipients will place protocols on security and confidentiality required by the CTA to protect sensitive personally identifiable information. While it largely tracks the 2022 proposal, it also includes certain material changes to substance and procedure.

The Access Rule becomes effective February 20, 2024, but will be phased in over an extended period of time. In this Legal Update, we provide background regarding the Access Rule, discuss some of the key changes from the proposed rule, and note the Access Rule's implications for financial institutions ("FIs").

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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