Financial Crime: FinCEN final rule on beneficial ownership

September 2022

With the issuance of FinCEN’s long-anticipated final rule on beneficial ownership, companies should expect strengthened regulatory attention in such areas as due diligence, SAR filings, and anti-corruption compliance programs. (Note: FinCEN’s rule for reporting beneficial ownership information is the first of three rulemakings that will implement the provisions of the Corporate Transparency Act and inform the content of a national database on corporate ownership. The additional rulemakings will (1) establish rules for who may access BOI, for what purposes, and the safeguards that will be required to ensure the information is secured and protected; and (2) revise FinCEN’s customer due diligence rule following the promulgation of the BOI reporting final rule.)