The customer is a US corporation that is owned by a parent company that is a foreign company and the beneficial owners will be foreign persons.
Is this customer exempt due to foreign persons as beneficial owners?

No, foreign owned businesses are neither excluded nor exempt from beneficial ownership rules.

OK that is what I thought but wanted to double check. Thanks Brian!

I have new information- American business owned by a publicly traded company from Japan....

Believe I found my answer on the FAQs. They are not exempt.

Correct. I laughed out loud when I first read the FAQs. Someone obviously wanted to exclude this businesses so badly, that FinCEN had to devote two questions two it.


Q.24 Are foreign publicly traded companies excluded? No.


Q.25 Can be make a risk based decision to exclude foreign publicly traded companies even though you just told us they are not? No.