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.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!