Since the US District Court issued an injunction blocking the Corporate Transparency Act, what do we do if a customer refuses to provide their beneficial ownership information at account opening?

Answer:

Although this ruling prohibits FinCEN from mandating that reporting companies submit beneficial ownership information to the FinCEN database, this rule does not impact the 2018 Customer Due Diligence Rule which requires financial institutions to obtain beneficial ownership information from legal entities opening new accounts or have a change in their risk profile. If a customer refuses to comply with a request for obtaining due diligence information including beneficial ownership, the institution should refuse to open the account and consider if a SAR is required based on the refusal to provide information.