FinCEN CDD FAQ: Do covered financial institutions now have additional obligations under Section 314(a) for beneficial ownership information?

Compliance > BSA > FinCEN CDD/BO Rule - eff 2016
Q:  Do covered financial institutions now have additional obligations under Section 314(a) for beneficial ownership information?
 
A.  FinCEN does not expect the information obtained under the CDD Rule to add additional 314(a) requirements for financial institutions.  The regulation implementing section 314(a) does not require the reporting of beneficial ownership information associated with an account or transaction matching a named subject in a 314(a) request.  Covered financial institutions are required to search their records for accounts or transactions matching a named subject and report whether a match exists using the identifying information provided in the request.
 
 
 
This FAQ, and others, was released in July 2016.  The 2016 FAQs were issued to assist institutions in understanding the scope of the Customer Due Diligence (CDD) requirements that were published in May 2016.   They may be found here:  https://www.fincen.gov/statutes_regs/guidance/pdf/FAQs_for_CDD_Final_Rule_(7_15_16).pdf
 

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