On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018.
- The FAQ addresses the following topics, among others:
- Beneficial Ownership Threshold
- Interaction of the beneficial ownership threshold with other AML program obligations
- Collection of beneficial ownership information for direct and indirect owners: Legal entity customers with complex ownership structures
- Identification and Verification methods
- Collection of beneficial ownership information
- Retention of beneficial ownership information
- Obligation to solicit or update beneficial ownership information absent specific risk‐based concerns
- Monitoring and updating information
- Definition of legal entity, charities, non‐profits, etc.
- Private Label Retail Credit
- Equipment Finance and Lease Exemption
- Treatment for CTRs
- Impact of the rule on AML process
- Customer relationship/Customer risk
One of the big questions out there is whether business account loan renewals or certificate of deposit rollovers require a certification at the time of renewal. Check out Question 12 for the important details!
These FAQs are a supplemental document to the first set of FAQs issued as FIN‐2016‐G003 back on July 19, 2016.
Join us on Tuesday, April 10, 2018 for a special Tuesdays with TCA webinar discussing the newly‐published FAQs for Customer Due Diligence/Beneficial Ownership. Contact us at [email protected] or (800) 934‐7347.
