Skip to content

Beneficial Owner Certification

Answered by: 

Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?

Yes. You are required to identify all direct or indirect beneficial owners with more than 25% ownership interest in your customer plus one control person who may or may not be one of the three beneficial owners of ABC LLC.

FinCEN addresses this scenario in Question #3 of its April 2018 Beneficial Ownership FAQs.

First published on 08/09/2020

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics