I am looking to gain an understanding of what other FIs are doing ahead of what is likely to be a final FinCEN rulemaking concerning beneficial ownership.

When establishing new relationships with domestic entities (all types, including but not limited to, corporations, LLCs, partnerships,etc.), is your FI currently:

1. Identifying beneficial owners through business documentation and/or Officer attestation and obtaining minimimum identifying information, including name, address, TIN, and date-of-birth?
2. Screening beneficial owners against OFAC and PEP databases?
3. Verifying the identities of beneficial owners through either documentary or non-documentary verification in instances whereby they are also signatories?

Any/all guidance is greatly appreciated.

For all 10%+ owners, who are not signers on the account, we get their names and OFAC check them.

Since most stated do not post who the beneficial owners of a corporation are (and can change) other than taking the customer at their word and obtaining formation documents. In most state verifing by any documentary means is not plausable. As above we ofac/cip names given and signers.