Does anyone use FinCEN ID as an identification number of a legal entity customer on CTRs and SARs? We are thinking of doing it, but wanted to understand the opinions of the industry experts first.

Thank you.

Regardless of what information a legal entity is providing to FinCEN to comply with the Corporate Transparency Act, there have been no changes to the filing instructions for CTRs, SARs, or to Section 326 of the USA PATRIOT Act that would permit you to accept a FinCEN Unique Identifier.

Just today, FinCEN published a published a request for comment (link below) to inquire about the possibility of only collecting a truncated social security number to comply with CIP requirements, but that would still be contingent on the financial institution's ability to obtain the full social security number using "reputable third-party sources."

https://www.fincen.gov/news/news-re...tomer-identification-program-requirement