Implementing the New Beneficial Ownership Rules


On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN) issued its final rule to implement the long awaited beneficial ownership rules that will significantly impact customer due diligence requirements. Under the final rule, a covered financial institution will be required to adopt due diligence procedures that will require identification and verification of a legal entity’s beneficial owner(s) at the time of account opening.

In addition, another pillar has been added to the existing four pillars that have encompassed anti-money laundering programs since the passage of the USA PATRIOT Act. The requirement to establish risk-based procedures for conducting ongoing due diligence, including customer risk profiles, will have a major impact on your financial institution's anti-money laundering program.


The new beneficial ownership rules will require a financial institution to implement the most significant change to its BSA/Anti-money laundering program in the past decade. This two-hour webinar provides the details necessary to begin to prepare for this significant change. Whether you are the BSA Officer or a new account representative for your financial institution, the beneficial ownership rules will have a considerable impact on your daily requirements.

Covered Topics:

Upon completion of the program participants will understand: 

  • What is considered a covered financial institution under the beneficial ownership rules
  • The written procedural requirements necessary under the new rule
  • How to define a “legal entity customer”
  • The two types of beneficial owners: “ownership prong” and “control prong”
  • Which legal entity customers are excluded or exempted from the identification and verification requirements
  • What type of accounts are exempt from the identification and verification requirements
  • The model form provided by FinCEN to satisfy the identification requirements
  • How to develop a customer risk profile as part of the risk-based due diligence requirements
  • What type of ongoing monitoring is necessary under the new rules
  • Options for gathering beneficial ownership information for owners with less than 25% ownership
  • Changes to existing written policies, procedures and training programs; and
  • The record retention requirements.

Who Should Attend?

Front-line/new account personnel, BSA Officers, compliance officers, auditors and others with responsibilities for monitoring BSA related activities