Archive

FINCEN ISSUES ANPRM ON BENEFICIAL OWNERSHIP REPORTING

On April 1, 2021, FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on new beneficial ownership reporting provisions included in the Corporate Transparency Act/Anti-Money Laundering Act of 2020, which was passed into law as part of the National Defense Authorization Act of 2021 on January 1, 2021. The ANPRM, published in the Federal Register on April 5, 2021, is requesting input on procedures and standards for reporting companies to submit information to […]

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FinCEN PROVIDES RELIEF FROM BENEFICIAL OWNERSHIP RULES FOR ROLLOVERS AND RENEWALS

On Friday, September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) issued a ruling which grants certain exceptions for financial institutions from the Beneficial Ownership Rule. Specifically the ruling provides financial institutions relief from the obligations under the Beneficial Ownership Requirements of identifying Legal Entity Customers in the case of: •A rollover of a certificate of deposit (CD) •A renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not […]

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EXTENSION OF LIMITED EXCEPTION TO BENEFICIAL OWNERSHIP RULE

On August 8, 2018 Financial Crimes Enforcement Network (FinCEN) announced a 30-day extension to the limited exception to the Beneficial Ownership Rule   On May 16, 2018, FinCEN issued a 90-day limited exceptive relief to covered financial institutions from the obligations of the Beneficial Ownership Rule for Legal Entity Customers (Beneficial Ownership Rule) for certain financial products and services (i.e., certificate of deposit or loan accounts) that were established before the Beneficial Ownership Rule’s Applicability […]

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FINCEN ISSUES BENEFICIAL OWNERSHIP DELAY IN REGARDS TO RENEWALS AND ROLLOVERS

On Wednesday, May 16th, FinCEN issued a ruling that provides covered institutions a 90-day period of limited exceptive relief to their requirements under the Beneficial Ownership Rule. This exception applies to products and services that are set to automatically rollover or renew (CD or loan accounts) that were established before May 11, 2018. This exception came just five days after the mandatory compliance date of the Beneficial Ownership Rule had passed. This relief period will […]

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NEW CUSTOMER DUE DILIGENCE AND BENEFICIAL OWNERSHIP EXAMINATION PROCEDURES

On May 11, 2018, the effective date of the Beneficial Ownership requirements, the Federal Financial Institutions Examination Council (FFIEC) issued new examination procedures on the final rule, “Customer Due Diligence Requirements for Financial Institutions,” issued by the Financial Crimes Enforcement Network (FinCEN) on May 11, 2016. The examination procedures apply to banks, savings and loan associations, savings associations, credit unions, and branches, agencies, and representative offices of foreign banks. The new examination procedures replace those […]

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