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314(a) and Beneficial Ownership rules

Do 314(a) expectations apply to Beneficial Ownership rules?

Quoting from the FAQs on the rule: “FinCEN does not expect the information obtained under the CDD Rule to add additional 314(a) requirements for financial institutions. The regulation implementing section 314(a) does not require the reporting of beneficial ownership information associated with an account or transaction matching a named subject in a 314(a) request. Covered financial institutions are required to search their records for accounts or transactions matching a named subject and report whether a match exists using the identifying information provided in the request.

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First published on 03/24/2019

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