Archive

Go to:

November 2018
SMTWTFS
123
45678910
11121314151617
18192021222324
252627282930
< Oct Dec >
Leaguer Email Subscription

You are not currently subscribed. Click Subscribe below to receive the Leaguer email.

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule
Tuesday, September 11, 2018 6:35 AM

The Financial Crimes Enforcement Network is now granting exceptive relief to covered financial institutions1 from the obligations of the Beneficial Ownership Requirements for Legal Entity Customers (Beneficial Ownership Rule) and its requirement to identify and verify the identity of the beneficial owner(s) when a legal entity customer opens a new account as a result of the following:

  • A rollover of a certificate of deposit (CD) (as defined below);
  • A renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not require underwriting review and approval;
  • A renewal, modification, or extension of a commercial line of credit or credit card account (e.g., a later payoff date is set) that does not require underwriting review and approval; and
  • A renewal of a safe deposit box rental.


The exception only applies to the rollover, renewal, modification, or extension of any of the types of accounts listed above occurring on or after May 11, 2018, and does not apply to the initial opening of such accounts2. Notwithstanding this exception, covered financial institutions must continue to comply with all other applicable anti-money laundering (AML) requirements under the Bank Secrecy Act (BSA) and its implementing regulations, including program, recordkeeping, and reporting requirements.

View the detailed ruling, including covered product descriptions and characteristics.

1 “Covered financial institutions” are banks, brokers or dealers in securities, mutual funds, futures commission merchants, and introducing brokers in commodities.

2 Covered financial institutions are not excepted from the obligation to identify and verify the identity of the beneficial owner(s) of legal entity customers at the initial account opening for such accounts occurring on or after May 11, 2018.