Jim Kalabokis

Question and Answer

What is a financial institution’s (FI) responsibilities as it relates to legal entities registering Beneficial Ownership information with FinCEN? Can we access the system now? Do we need to do anything differently?

Answer: There have been no changes to the FI’s current requirements to obtain beneficial ownership information. The FAQs stated that FI’s are not currently required to access the beneficial ownership IT (BO IT) system. Access to the system is expected to be extended to FIs in the spring 2025. FinCEN intends to provide additional guidance […]

What is a financial institution’s (FI) responsibilities as it relates to legal entities registering Beneficial Ownership information with FinCEN? Can we access the system now? Do we need to do anything differently? Read More »

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How do I complete Part II (Amounts and Dates) on a continuing activity suspicious activity report (SAR) if the transaction took place on a single date? Do I include the investigation range from the previous filing?

Answer: The date field in Part II should only cover the date range of activity determined to be suspicious, not the investigation range. If transaction occurred on a single date, the “To” field is left blank. Describe the time period of the investigation in the narrative.

How do I complete Part II (Amounts and Dates) on a continuing activity suspicious activity report (SAR) if the transaction took place on a single date? Do I include the investigation range from the previous filing? Read More »

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