I apologize if this has already been discussed and I just didn't find it. My understanding is we aren't required to do 314(a) checks on beneficial owners, The way our system currently is, they wouldn't be in the database and wouldn't get included in the check. What is everyone else doing on this?

I believe it was addressed in the private forums, as this is a sensitive topic.

From the Preamble (public information)

FinCEN does not expect the information obtained pursuant to the beneficial ownership requirement to add additional requirements with respect to Section 314(a) for financial institutions. The rule implementing Section 314(a), set forth at 31 CFR 1010.520, does not authorize the reporting of beneficial ownership information associated with an account or transaction matching a named subject.

If you were to get a "hit" on a beneficial owner you simply don't have enough information for it to be worth law enforcement's time; i.e. they probably knew that much already.

Ok, that makes sense. Thank you.