Financial Crimes Enforcement Network Reference Guide Clarifies Beneficial Ownership Reporting Requirements

Attorneys Andres Fernandez, Gabriel Caballero, Daniel Noste, Michael Titens, Alan Granwell, Catherine Yepes and Kristen Jimenez, members of Holland & Knight Financial Services and Corporate Transparency Act teams, co-authored an article included in The Banking Law Journal about the Financial Crimes Enforcement Network's (FinCEN) new reference guide for reporting beneficial ownership information (BOI). The article explains the key differences between BOI reporting requirements under the Customer Due Diligence (CDD) Rule for financial institutions and the Corporate Transparency Act (CTA) for certain entities. It highlights the distinct purposes, information collected and reporting deadlines for each regime, emphasizing that compliance with one does not fulfill obligations under the other. The authors also discuss the implications for entities and financial institutions, noting that further guidance is expected as FinCEN works to align CDD requirements with the CTA.

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