BSA Beneficial Ownership Rule: Guidance, Best Practices, and Lessons Learned

It has been over a year since FinCEN implemented the Beneficial Ownership Rule. Yet, beneficial ownership continues to be a complex and evolving area that can be difficult to wrap your arms around. Institutions are having legal, compliance, and operational challenges associated with beneficial ownership reporting. Join our expert, Coppelia Padgett, as we look at the regulation, FinCEN FAQs, other guidance and collective “lessons” learned. Bring your questions as we provide a road map through this regulatory and practical maze to help you understand and organize your BSA/AML program so that it minimizes your risks, complies with the new legal and regulatory requirements.

Some of the issues and questions we will be answering include:

• How to Identify Beneficial Owners for Legal Entity Customers
• What Legal Entity Customers Can Be Exempt from the Rule
• How to Handle Legal Entity Customers with Complex Legal Structures
• Using the Ownership Prong and the Control Prong Definitions in Real Situations
• What Is a “New” Account and Do Existing Customers Have to Comply
• Can CIP and Beneficial Ownership Verification Procedures Be Different
• How CTRs and SARS Will Be Affected by the New Rule
• Does Beneficial Ownership Affect OFAC, Sanctions, 314a or PEPs
• What Are the Strategies & Next Steps to Get Ready for This Change
• What Is the Equipment Finance and Lease Exemption
• What Issues Are the Latest 37 Questions of Guidance Trying to Clarify
• Lessons learned from recent experience with the Beneficial Ownership Rule