On September 7, 2018, the Financial Crimes Enforcement Network
(FinCEN) issued Ruling FIN-2018-R003 (the
"Ruling") to exempt covered financial institutions (CFIs)
from the requirement to collect beneficial ownership information on
legal entity customers (such as corporations, limited liability
companies and partnerships) in connection with specified rollovers,
renewals, modifications and extensions of certain
accounts.
The general beneficial ownership due diligence requirements for
CFIs are set forth in a FinCEN regulation with a required
compliance date of May 11, 2018 (the "Beneficial Ownership Rule").
The new Ruling replaces and supersedes FinCEN's May 16, 2018 ruling, which provided a
temporary exemption from the Beneficial Ownership Rule requirements
for CFIs in the case of certain rollovers, renewals, modifications
and extensions.
