FinCEN recently published changes to the Beneficial Owner Certification Form (Appendix A to 31 CFR 1010.230). These technical corrections were effective September 28, 2017, and include 
the following:
- Part I
In the first sentence under the “What information do I have to provide?” heading, the term “foreign persons” is changed to “non-U.S. persons”.
- Part II
The heading for Section II b. is changed to “b. Name, Type, and Address of Legal Entity for Which the Account is Being Opened:”.
- Tables in Section II c and Section II d
In the headings of the last column, the term “Foreign Persons” is changed to “Non-U.S. Persons” and the term “Social Security Number” is added after the term “persons”.
- Footnote 1
The term “Foreign Persons” is changed to “Non-U.S. Persons” and “a Social Security Number,” is inserted after the word “provide”.
It’s important to note the addition of the “type” of legal entity business (corporation, LLC, etc.) as a required piece of information and the addition of “Social Security Number” as an acceptable identifying number for non-U.S. persons. This will require adjustments in the implementation plans of financial institutions and third-party service providers.
Due to these changes, we have updated our Certification of Beneficial Ownership form that’s available in the BSA Tools (Free Downloads) on our website.
Also, if you are looking for an update on all the BSA happenings in 2017 and what’s to come with the May 11, 2018, Final Rule, you’re in luck! Join us for our full day BSA/AML Compliance Conference in November.
Published
2017/10/09
Deb Irving